Last Updated: June 2019
- The identity of the controller
You are hereby informed that Data that you provide are subject to an automated data processing whose controller is Information Asset or one of its entities or a subsidiary which contact details are indicated at the bottom of each data collection form.
- Collection of Data
We may collect Data about Our client, prospects and visitors.
Your Data are collected when you install, access, or use the Platforms and/or the Services, and when you otherwise interact with us.
We do not collect sensitive information of you (e.g., data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation). We shall, where necessary, obtain your explicit consent to collect and use such information.
Data We collect falls into the following categories:
- Identifying information and civil status;
- information about your company and current position;
- Usage of Services and products
- login information;
- location information.
These Data are gathered directly from you via the Data collection form or indirectly through automated methods.
We may combine Data you provide Us with Data that are collected through automated methods.
2.1. Information you provide to Us
We process Data you provide directly to Us, in particular when you complete a data collection form.
For example, we collect Data when you create an account, access one of the Platforms, use the Services, participate in a contest or promotion, register for an event or an online course, apply for a job, request customer support or otherwise communicate with Us.
The Data may include the following data as well as any other type of information that we specifically request you to provide to Us through Our collection forms, such as:
- email address,
- postal address,
- phone number,
- information about your company and current position.
Our collection forms will indicate as to whether replies are mandatory or not and the consequences of a possible failure to reply.
2.2. Data We collect automatically when you use the Services
When you access or use Our Services, we automatically collect the following information about you:
- Identification Information: In general, when you fill out questionnaires on one of Our Platforms, subscribe to one of Our Services or ask us to contact you, you may provide us with your contact details (your name, (professional) email address, your (professional) contact details, such as telephone number, address, country and social media information).
- Log Information: We log information about your use of the Platforms and/or the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to Our Services.
- Device Information: We collect information about the computer or mobile device you use to access Our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
- Location Information: We may with your consent collect information about the location of your device each time you access or use one of Our mobile applications. If you initially consent to Our collection of location information, you may be able to subsequently stop the collection of these Data through your device operating system settings. You may also stop Our collection of location information by following the standard uninstall process to remove Our mobile applications from your device.
2.3. Information we collect automatically through Cookies and other tracking technology
A “cookie” is a small text file that is placed onto an Internet user’s web browser or device and which is used to record information related to the navigation or the use of a device or a website.
A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags (also known as “tracking pixels”). It may be used on our Platforms or in Our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. For more information about cookies, and how to disable them, please see “Your Choices” below.
Some of the cookies are used for the exclusive purpose of enabling or facilitating communication or are strictly necessary for the provision of Our Services.
These are essentially of session cookies for authenticating and connecting to the Services, as well as memorizing navigation items during a session.
You have the ability to decline cookies by changing the settings on your browser but this might prevent you from benefiting from some elements of the Services. You can also consult or destroy cookies if you wish, since they are stored on your hard disk.
We may also use these technologies for other purposes than the Services operation such as:
- To improve Our Services;
- To gain insight in the way you use Our Services and/or Our Platforms;
- To enable single sign on
- To remember you, for your convenience, when you visit one of Our Platforms and/or Our Services;
- To provide you with advertising tailored to your interests;
2.4. Data We collect from other Sources
We may also obtain information from other sources and combine that with information we collect through Our Services. For example, if you connect a Information Asset account with your social media account, we may have access to certain information from the company that owns or operates the social media account in accordance with the authorization procedures determined by such social media company.
Additionally, Information Asset may receive information about you from other third parties whom you have authorized to share your information or who collect information in connection with co-branded offerings.
2.5. Third Party Cookies
When you access or use Our Services, one or more cookies from third party are likely to be placed on your equipment.
We inform you that We have no access and cannot exercise any control over third party cookies. However, we shall ensure that the partner companies agree to process the information collected on Our Services in compliance with the Regulations and undertake to implement appropriate measures for securing and protecting the confidentiality of the Data.
- How we use the Data
Information Asset collects and processes your personal information in order to offer you a safe, comfortable, and personalized experience each time you visit the Website or utilize our Services.
With that said, your personal data will only be processed for the following (internal) purposes:
- Provide, maintain and improve Our Services;
- Provide and deliver the Services you request, process transactions and send you related information, including confirmations and invoices;
- Send you technical notices, updates, security alerts and support and administrative messages;
- Respond to your comments, questions and requests and provide customer service;
- Communicate with you about products, services, offers, promotions, rewards, and events offered by Information Asset and others, with your prior consent, and provide news and information we think will be of interest to you;
- Monitor and analyze trends, usage and activities in connection with Our Services;
- Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
- Process and deliver contest entries and rewards;
- Link or combine with information we get from others to help understand your needs and provide you with better service; and
- Carry out any other purpose for which the information was collected, and which is necessarily contemplated by the collection of such information or is otherwise explicitly mentioned in the process of collection.
According to the Regulation, each Data processing is performed on one of the following legal basis:
- Your consent;
- The performance of the Service subscribed by you.
- The legitimate interests pursued by Us or by a third party, except where such interests are overridden by your interests or your fundamental right and freedoms.
- How we share your Data
The following persons may receive the Data:
- Our subsidiaries;
- Our Data processor;
- Our trading partners.
- In connection with a joint marketing campaign, seminar, Information Asset product offering or other product or service offered by Information Asset in conjunction with a third party, we may share your information with any third parties participating in such offering and such parties may use this information for their direct marketing purposes. Please see “Your Rights to Information about Sharing” below for more information about this sharing.
- With vendors, consultants and other service providers who need access to such information to carry out work on Our behalf;
- In response to a request for information if we are required by, or believe disclosure is required by, any applicable law, regulation or legal process, including in connection with lawful requests by law enforcement, national security, or other public authorities;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of Our business to another company; and
- With your consent or at your direction, including if we notify you through Our Services that the information you provide will be shared in a particular manner and you provide such information.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
- The period of Data retention
Data are retained in a form that allows your identification for a period no longer than is necessary for the purposes for which they are obtained and processed. Data shall be retained for a period of five years after the last interaction or the termination of the business relation.
For more information, please refer to the period retention specified onto our Data collection forms.
- Data transfer
6.1. How we transfer your Data
6.1.1. Privacy Shields self-certification
We inform you that Data could be transferred outside European Union only with adequate safeguards.
All transfers shall be made to:
- a country recognized by the European Commission as providing an adequate level of protection;
- a company located to the United State and that has adhered to the Privacy Shield Framework;
- a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission.
6.1.2. Online Complaint
In compliance with the Privacy Shield Principles, We commit to resolve complaints about our collection or use of your Data. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Us at:
6.2. EU-U.S. Privacy Shield Framework
Information Asset adheres in its processing of personal data received from the EU (“EU Data”) to the EU-U.S. Privacy Shield Framework Principles established by the U.S. Department of Commerce and the European Commission (the “Principles”). For more information about the Principles, please visit the Department of Commerce’s Privacy Shield website.
Please direct any inquiries or complaints regarding Our compliance with the Principles to the point of contact listed in the “Contact Us” section below. Information Asset is subject to the investigatory and enforcement powers of the FTC. If Information Asset shares EU Data with a third-party service provider that processes the data solely on Information Asset’s behalf, then Information Asset may be held liable for that third party’s processing of EU Data in violation of the Principles, unless Information Asset can prove that it is not responsible for the event giving rise to the damage.
We are committed to taking appropriate security measures on both a technical and an organisational level, designed to keep your Data secure. Our technical, administrative and physical procedures are designed to protect Data from loss, theft, misuse and accidental, unlawful or unauthorized access, disclosure, alteration, use and destruction. We follow generally accepted standards to protect the personal information submitted to Us, both during transmission and once it is received.
We shall not be liable in any way for direct or indirect damages caused by a wrongfully or improper use of the personal data by a third party.
At the same time, you also share responsibility for maintaining the privacy and security of the Services, for example: by not allowing any third party to use your personal account on the Services and avoiding all other non- authorized access to your login and access code. You are solely responsible for the use of the Services on your devices, IP-address and identification data, as well as for its confidentiality.
In any case, you need to immediately notify Us of any unauthorized use of your personal Account by sending an e-mail to firstname.lastname@example.org.
If you have any questions about the security of your personal information, you can contact Us at email@example.com.
- Your rights
8.1. Right of access and right to obtain a copy
8.2. Right to rectification, erasure or restriction
You have the choice to share your Data with Us.
You also have the right to request Us to rectify your Data. Please note that you can change your account information by submitting updated Data in the registration form.
You can also request the processing of your Data to be restricted, if you think your Data is inaccurate and you subsequently notified Us about this.
Additionally, you have the right to request Us to erase your Data in as far we were not able to anonymize it.
Yet, with regard to certain Data provided by you, We are bound by certain legal obligations, pursuant to which Us is not allowed to delete the information.
Furthermore, you acknowledge that a refusal to share Data or a request to erase these Data will make the delivery of several Our Services impossible.
8.3. Right to object:
You have the right to object to the processing of your Data when you have serious and legitimate reasons to do so.
You also have the right to object to the use of your Data for purposes of direct marketing by clicking on the unsubscribe function in the communication or by sending Us a request to do so. In such cases specific reasoning will not be requested.
8.4. Right to data portability:
You have the right to obtain your Data which is processed by Us in a structured, commonly used format and/or to transfer this Data to another data controller.
8.5. Right to withdraw consent:
When the processing is based on prior consent you have the right to withdraw this consent.
8.6. Automated decisions and profiling:
You have the right to request Us not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
8.7. Exercising your rights:
You may exercise your rights by contacting Us in writing, with a proof of your identity, at the address provided in the “Contact Us” section below or at the address provided in our Data collection form or by sending us an email to firstname.lastname@example.org. The copy or proof of your identity shall only be used to identify you and to authenticate your request. After the authentication process, the copy of your identity card and the personal data pertaining thereto shall immediately be deleted. We inform you that you also may update, correct or delete by yourself your account information by logging into your online account.
Especially regarding promotional or sales communications, you may opt out of receiving promotional or sales communications from Information Asset by following the instructions provided in those communications or by sending an email to email@example.com. If you email Us to unsubscribe from Our commercial email messages, please include the word “UNSUBSCRIBE” in the email subject line. Please note that if you opt out of receiving promotional communications, we may still send you transactional or relationship messages, such as those about your account or Our ongoing business relations.
You can also contact Us by sending an email to firstname.lastname@example.org to request to be removed from Our sales call list.
- Contact Us
Information Asset LLC
Harrington Park, NJ
Soares Enterprises (India) LTD – Mumbai
Sonawala Industry Estate, Goregaon East, Mumbai, India
Soares Enterprises (India) LTD – Mumbai
Sonawala Industry Estate, Goregaon East, Mumbai, India