1. OUR approach to privacy
1.4 Centific is the data controller of the personal information we hold about you.
2. Personal INFORMATION we COLLECT about you AND HOW WE USE IT
2.1 We collect personal information about you when you voluntarily submit information directly to us when you use our Website. This can include information you provide to us when you fill in a form on our Website, correspond with us via the Website, phone, e-mail or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to surveys or use some other feature of our Website as available from time to time.
2.2 If you choose not to provide personal information, we may not be able to respond to your requests.
2.3 The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information, the categories of recipients of the personal information and information as to how we determine applicable retention periods.
2.4 We also automatically collect personal information about you indirectly about how you access and use the Website and information about the device you use to access the Website.
2.5 The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information, the categories of recipients of the personal information and information as to how we determine applicable retention periods.
2.6 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.
2.7 We may anonymize and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving our Website and developing new products and features. We may also share such anonymised information with others.
3. MARKETING AND RELATED COMMUNICATIONS
From time to time we may contact you with relevant information about our Website and services. Most messages we send will be by email. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you. If you do not want to receive such messages from us, you can change your marketing preferences by clicking on the unsubscribe link at the bottom of our emails.
4. Storing and transferring your personal information
4.1 Security. We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on secure servers. All electronic transactions entered into via our Website will be protected by SSL encryption technology.
5. YOUR RIGHTS IN RESPECT OF your personal information
5.1 If you are located in the EU, in accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
(a) Right of access. The right to obtain access to your personal information.
(b) Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
(c) Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
(d) Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
5.3 You also have the right to lodge a complaint to the Supervisory Authority in your jurisdiction.
6. cookies and similar technologies
6.2 Cookies are pieces of code that allow for personalization of our Website experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes.
6.3 We use the following types of cookies:
(a) Strictly necessary cookies. These are cookies that are required for the essential operation of our Website such as to authenticate users and prevent fraudulent use.
(b) Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognize you when you return to our Website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(d) Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
6.5 If you only want to limit third party advertising cookies, you can turn such cookies off by visiting the following links (please bear in mind that there are many more companies listed on these sites than those that drop cookies via our Website):
(a) Your Online Choices (http://www.youronlinechoices.com/ )
(b) Network Advertising Initiative (http://www.networkadvertising.org/)
(c) Digital Advertising Alliance (http://www.aboutads.info/consumers)
7. Links to third party sites
Our Website may, from time to time, contain links to and from third party websites, such as news publications. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
8. OUR POLICY TOWARDS CHILDREN
Our Website is not directed at persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information.
9. Changes to this policy
10. Notice to you
11. Contacting us
ANNEX 1 – PERSONAL INFORMATION WE COLLECT
|Category of personal information||How we use it||Legal basis for the processing||Categories of recipients||Retention period|
|Basic personal details and contact information. Personal information voluntarily provided via our Website, such as your first name, last name, country of residence and e-mail address.||We use this information to communicate with you to deal with queries made by you and, where you have subscribed to stay connected with us, for marketing purposes such as sending you updates.||The processing is necessary for our legitimate interests, namely for communicating with individuals that have corresponded with us and for marketing purposes.||As required in accordance with how we use it, we will share your personal information with the following:Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include identifying and serving targeted advertisements, providing mailing or email services, tax and accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services.Purchasers and third parties in connection with a business transaction. Personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Website or to protect the security or integrity of our Website; and/or (c) exercise or protect the rights, property, or personal safety of Centific, our customers or others.||For no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.|
|Correspondence and comments. When you contact us directly, e.g., by email, phone, mail or by completing an online form on our Website, we will record your correspondence and comments.||We use this information to address your questions, issues and concerns and to deal with queries made by you, and to improve our Website where you have provided feedback.||The processing is necessary for our legitimate interests, namely to deal with queries; provide responses to individuals that have corresponded with us and improve our Website.|
|Location Information. Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location.||We may use an approximate location to ensure content on our Website is relevant to the city or country you are using your device in.||The processing is necessary for our legitimate interests, namely to tailor our Website to the user and to improve our Website generally.|
|Subscription status. I.e. whether you provided your email via the subscription box, including the time submitted and your IP address.||We use this information to keep a record of your subscription status and to provide you with appropriate updates / marketing communications.||The processing is necessary for our legitimate interest, namely ensuring the user receives the correct updates / marketing communications.|
|All personal information set out above.||We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Website, to communicate with you, to monitor and improve our Website and business, and to help us develop new services.||The processing is necessary for our legitimate interests, namely to administer and improve the Website, to improve our business and develop new services.|
ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY
|Category of personal information||How we use it||Legal basis for the processing||Categories of recipients||Retention period|
|Information about how you access and use the Website. For example, the website from which you came and the website to which you are going when you leave our Website, how frequently you access our Website, the time you access our Website and how long you use it for, whether you open emails or click the links contained in emails, whether you access the Website from multiple devices, and other actions you take on the Website.||We use this information to present our Website to you on your device; and to monitor and improve our Website.||The processing is necessary for our legitimate interests, namely to ensure our Website is presented to you correctly and to monitor and improve our Website.||As required in accordance with how we use it, we will share your personal information with the following:Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include identifying and serving targeted advertisements, providing mailing or email services, tax and accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services.Purchasers and third parties in connection with a business transaction. Personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business. Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Website or to protect the security or integrity of our Website; and/or (c) exercise or protect the rights, property, or personal safety of Centific, our customers or others.||For no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.|
|Information about your device. We also collect information about the device you use to access our Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Website through the device, your Internet service provider or mobile network and your IP address.|
Last Updated: January 2020