This policy (together with and any other documents referred to in it) sets out:
1. What Information Do We Collect?
We may process your personal data if:
- You or the company you work for are a customer or a supplier of ours.
- You or the company you work for use our products or services.
- You work for a customer or a supplier of ours, or for someone who uses our products or services.
- You are someone (or you work for someone) to whom we want to advertise or market our goods or services.
(a) Information We Collect from You or a Third Party
Personal Data is information that identifies you personally either directly, such as your first and last name, telephone number and Email address or indirectly by a reference code or online identifier (“Personal Data”).
We may process your Personal Data that we have either obtained from you or obtained from somewhere else. Personal Data relating to you that we process may include:
- Your name.
- Who you work for, and your job function or department.
- Your address, phone number, Email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the company that you work for).
- Information about you that you give us by communicating with us by phone, by Email, via our website, via social media, trade shows and events or otherwise. It includes information you give us or that we obtain when you use our Site, obtain or subscribe to our goods or services, supply us with goods or services, enquire about a product, place an order, enter a competition, promotion or survey, or contact us to report a problem, or do any of these things on behalf of the person that you work for.
- Information relating to transactions with us involving you or the company you work for (for example, details of goods or services that we have supplied to, or obtained from, you or the person you work for).
- Other information relating to you which it is necessary for us to process in order to enter into or perform a contract with you or the company you work for (for example, right to work information and information obtained from credit references agencies where this is necessary to enable us to carry out appropriate checks in relation to contracts with you or someone else that you work for or are otherwise related to).
- Information about events to which you or your colleagues are invited, and your personal information and preferences to the extent that this information is relevant to organising and managing those events (for example, your dietary
- Information relating to you that you give us, or we otherwise obtain when you visit us (for example, if you sign in or are recorded on CCTV while visiting us, or you give us the registration details of your vehicle).
We may collect this Personal Data through various methods and in various places on our Site, including contact us forms, requests for content or when you otherwise interact with our Site. Personal Data does not include data where the identity has been removed and re-identification is no longer possible (anonymous data).
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 offences.
(b) Information Collected or Stored as You Access and Use our Web Site
In addition to any Personal Data or other information that you choose to submit to us via our Site, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. To the extent we associate Usage Information with your Personal Data we collect directly from you on the Site, or any Usage Information could otherwise be used to identify you, we will treat it as Personal Data.
This Usage Information may include:
- your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;
- your Device functionality (including browser, operating system, hardware, mobile network information);
- the URL that referred you to our Site;
- the areas within our Site that you visit and your activities there, including remembering you and your preferences;
- your Device location;
- your Device characteristics; and
- certain other Device data, including date and time.
(c) Aggregated Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy notice.
2. How is Your Personal Data Collected?
We use different methods to collect data from and about you, including:
(a) Direct Interactions
You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, Email, providing us with your business card or other face to face interaction such as but not limited to us scanning your badge at a trade show or event. This includes Personal Data you provide when you request access to content or product demonstration, register for an event or webinar, submit a contact request, send us a direct Email or mail, or contact us by phone.
(b) Information Third Parties Provide About You
We may, from time to time, supplement the information we collect directly from you with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. Personal data which is not collected directly from you may be collected:
- From your employer in connection with your job and how it relates to us.
- If you use the Site or any other websites or apps operated by us.
- From third parties we work closely with in providing and supporting services to you, such as business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers.
(c) Tracking Technologies
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
- Cookies. A cookie is a data file placed on a Device when it is used to visit the Web A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.
- Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or Email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many Emails that were sent were actually opened or to count how many particular articles or links were actually viewed.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
- Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
- Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
(d) Tracking Technologies Usage
We may use Tracking Technologies for a variety of purposes, including:
- Targeting-Related. We may use Tracking Technologies to deliver content relevant to your interests on our Site and third-party sites, including advertising on third-party sites that you visit, based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.
(e) Tracking Technologies Choices and Consent
We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.
(e) Third Party Tracking and “Do Not Track.”
There may be other Tracking Technologies now and later devised and used by us in connection with the Site. Further, third parties may use Tracking Technologies in connection with our Site, which may include the collection of information about your online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
In connection with the above we may also work third party advertising networks that gather information about the content on our Site you visit and on information on other websites and services you visit. This may result in you seeing our advertisements when you visit other websites and services of third parties. For information on how to turn this feature off, see below or visit http://www.youronlinechoices.com/uk/
If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you do this will depend on the browser you use. Further details on how to control cookies using different browser settings is provided here: http://www.youronlinechoices.com/uk/five-top-tips
(g) Interactions with Third-Party Sites
3 How Do We Use the Information Collected?
(a) Information You Give to Us
We will use this information to:
- Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you or the company you work for and us including:
- supplying goods and services to you or the company you work for or receiving them from you or the company you work for, as the case may be;
- administering your/your company’s account with us;
- verifying and carrying out financial transactions in relation to payments you make in your own capacity or on behalf of your company;
- notifying you about changes to our service.
- Provide you with information about our products or services we feel may interest you or the company you work for, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See Our Sales and Marketing Updates and Communications.
- Ensure in our legitimate interests that:
- content from our Site is presented in the most effective manner for you and for your computer;
- we provide you or the company you work for with the information, products and services you request from us.
(b) Information We Collect About You from Your Use of Our Site
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- To administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To keep our Site safe and secure.
- For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- To improve our Site to ensure that content is presented in the most effective manner for you and for your computer.
- To allow you to participate in interactive features of our service when you choose to do so.
(c) Information We Receive from Other Sources
We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
(d) Our Sales and Marketing Updates and Communications
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your Personal Data for marketing analysis and to provide you with Sales and Marketing updates and communications about our products/services. You may cancel or modify our communications you receive from us at any time. For details on the options to make these changes see Section 6: How Do I Change My Information and Communications Preferences?
4. How and When Do We Share Information with Third Parties?
(a) Third Parties
We may share your Personal Data with appropriate third parties including:
- our business partners, customers, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
- our auditors, legal advisors and other professional advisors or service providers;
- credit reference agencies for the purpose of assessing your credit score where this is in the context of us entering into a contract with you or the person that you work for.
- Payment processing providers who provide secure payment processing services.
We may also use third-party vendors to perform certain services on behalf of us or the Site, such as hosting the Site, designing and/or operating the Site’s features, tracking the Site’s activities and analytics, or performing other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Data, to carry out the services they are performing for us and subject to contractual and other safeguards.
(b) Third-party analytics and other service providers who may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Data, about you in order to provide or support services to us in connection with the Site.
(c) To Protect the Rights of Nlyte and Others
(d) Affiliates and Business Transfer
5. Does Third-Party Content or Links to Third-Party Sites Appear on the Site?
The Site may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you. In addition, when you are on the Site you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Site onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Data, and may or may not have their own published privacy policies. We encourage you to note when you leave our Site and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them.
6. How Do I Change My Information and Communications Preferences?
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Site may allow you to review, correct or update Personal Data you have provided through the Site’s registration forms or otherwise, and you may provide registration updates and changes by contacting us here. If
so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that we may not be obliged in all cases to delete certain of your Personal Data from our databases and that data may remain on our systems for example where we have overriding legitimate grounds to process your Personal Data, including where needed to establish, exercise or defend legal claims or where required by law. When you edit your Personal Data or change your preferences on the Site, information that you remove may persist internally for Nlyte’s administrative purposes including where relevant for the purpose of evidencing our compliance with our legal obligations.
You may cancel or modify our Email marketing communications you receive from us at any time by following the instructions contained within our promotional Emails or in some cases by logging into your Site account and changing your communication preferences via the Nlyte Subscription Center, or by sending us an Email to email@example.com. This will not affect subsequent subscriptions and if you opt-out is limited to certain types of Emails, the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Site, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our sales or marketing communications.
You can also request that we send marketing material to a non-personal Email address instead of one which identifies you as an individual.
7. What About Transfers of Information outside the EEA?
The Personal Data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.
We may transfer your Personal Data outside the EEA:
- In order to store it.
- In order to enable us to provide goods or services to and fulfil our contract with you or the company your work for. This includes order fulfilment, processing of payment details, and the provision of support services.
- Where we are legally required to do so.
- In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
8. What About Security?
We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Data and have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Although we will do our best to protect your Personal Data, please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.
9. How Long Do We Keep Your Information?
We retain Personal Data for seven years or for as long as you have a contractual relationship with us in order to meet our obligations to you and for seven years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
10. What Are Your Rights?
You have the right under certain circumstances:
- to be provided with a copy of your Personal Data held by us;
- to request the rectification or erasure of your Personal Data held by us;
- to request that we restrict the processing of your Personal Data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your Personal Data, including the right to object to marketing (as mentioned in ‘Our Sales and Marketing Updates and Communications’ section);
- to request that your provided Personal Data be moved to a third party.
Your right to withdraw consent:
Where the processing of your Personal Data by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting via our form on our Contact Us page or by sending an Email to firstname.lastname@example.org. You can also change your marketing preferences at any time via our Subscription Center.
How to exercise your rights
You can also exercise the rights listed above at any time by contacting us via methods listed in the Contact Us section below
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your Personal Data, as well as deal with any complaints that you have about our processing of your Personal Data.
This policy was last updated on 23 May 2018.
12. Contact Us
Nlyte Software Limited is a company incorporated in England and Wales (registered company number 04805444) with its registered office address at Riverside House, 26 Osiers Road, London SW18 1NH, United Kingdom.
Postal Mail: Attention: Privacy Officer, Nlyte Software Limited, Riverside House, 26 Osiers Road, London, SW18 1NH
By Email: email@example.com
Nlyte Software Americas Limited, 2800 Campus Drive, Suite 135, San Mateo, CA 94403, Email: firstname.lastname@example.org
Nlyte Software Inc. 275 Raritan Center Parkway, Edison, NJ 08837, Email: email@example.com
Nlyte Software India LLP Regus Pune, Metropolitan Business Centre Private Limited, 4th floor, Baner, Pune, Maharashtra, 411045, India, Email: firstname.lastname@example.org