Effective Date 25 May 2018
Who are we?
Connexity, Inc. is a company incorporated in the State of Delaware, USA and has its principal office at 2120 Colorado Ave., Suite 400, Santa Monica, CA 90404.
Our data protection representatives can be contacted directly here: firstname.lastname@example.org or email@example.com.
Summary of key principles
We collect and process information about you when you provide it to us and when you use our Sites.
We typically use this information to send you materials you have requested to receive from us and to improve our Sites;
We may disclose this information to authorized third parties including our affiliates and third-party service providers for these purposes;
We encrypt any information you input using Secure Sockets Layer (SSL) software and take security measures to safeguard information in accordance with industry practice;
You have certain rights in relation to your personal data which you can exercise by following the links in section VII below;
If you have any questions or concerns about privacy at Connexity, please contact us by post (see below) or email at firstname.lastname@example.org or email@example.com;
Our Sites are not designed or intended for use by children under 16;
Where you are based in the EU, you may have certain additional rights which are set out in section VIII below.
I. What information do we collect about you and where do we collect it from?
(a) Information you give us: We collect your information when you choose to contact us via our Sites, where you request to be sent a copy of any materials we make available on our Sites or where you subscribe to receive our newsletters or email updates.
(b) Information we collect about you: We automatically collect certain information from you when you access our Sites including your IP address and information relating to your browser, operating system, ISP, how you use our Sites such as the web pages you visit, and the duration of your visits.
II. How we use & share the information collected
We use the information we collect about you for the following purposes:
- to improve our Sites; and
- to carry out your requests to be sent materials, newsletters and/or email updates and respond to your enquiries;
We process your information for the above purposes on the basis it is in our legitimate interests. You may object to processing by us for this reason at any time in accordance with section VII below.
We may disclose your information to:
- Our third-party service providers who perform functions on our behalf in connection with the operation of the Sites e.g., providers who host and manage data;
- Our third-party analytics partners to analyze Site traffic and understand customer needs and trends.
- Our parent company, subsidiaries or other affiliated companies (“affiliated companies”) for operational, marketing and promotional purposes;
- A third-party purchaser of all or any of our assets, where such information is one of the assets transferred;
- A prospective seller or buyer of our business or assets;
- A third party if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfil a government request, including for national security or law enforcement reasons; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Sites, or other users; or (d) in an emergency to protect the health and safety of our Sites’ users or the general public.
III. How long we store your information
The information we collect about you when you access our Sites (including referring URL, page visits, browser and/or device type, time and date) or that third parties collect on our behalf for purposes of website performance and analytics is deleted after 24 months.
We store the information you provide to us when you contact us by email for a period of up to 5 years.
IV. Cookies and similar technologies
We automatically receive and store certain types of information whenever you use our Sites by using “cookies” and analogous technology. “Cookies” are small files that we place on your computer or your Web browser memory to enable our systems to recognise your browser or device.
You may be able to direct your internet browser not to allow cookies and you can delete existing cookies from your computer.
V. Security of information
We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. We also use a secure server hosting location in the U.S., firewall protection, controlled access and encryption technology to protect your data. Please be advised, however, that while we strive to protect your information, we cannot guarantee or warrant the security of any information you disclose or transmit to us over the internet.
VI. Third- party policies
VIII. Additional provisions applicable to individuals in the European Union
- Your Rights
Where you are located in the European Union, in certain circumstances you are entitled to the following rights with respect to your personal data:
(a) Right to object to processing based on our legitimate interests: You have the right to object to us processing your personal data on the grounds of it being in our legitimate interests.
(b) Right to opt-out of receiving marketing communications: You have the right to opt-out of receiving marketing communications from us.
(c) Right to access, delete and correct your personal data: You have the right to request a copy of the personal data we hold about you, to delete and/or correct it.
(d) Right to be forgotten: In certain circumstances you can ask for the personal data we hold about you to be erased from our records.
(e) Right to restriction of processing: Where certain conditions apply to have a right to restrict the processing of your personal data.
If you think you are entitled to exercise any of the above rights and would like to do so, please contact us by clicking here.
IX. Privacy Shield
Connexity (and its wholly-owned subsidiary, Connexity Audience, Inc.) participates in the EU-U.S. Privacy Shield framework. Connexity is committed to subjecting all personal data received from EU member countries, in reliance on the Privacy Shield, to the principles underlying the Privacy Shield (the “Principles”). To learn more about the EU-U.S. Privacy Shield program, and to view Connexity’s certification, please visit the U.S. Department of Commerce site at https://www.privacyshield.gov/.
- Accountability for Onward Transfer
If we transfer personal data received from EU member countries, in reliance on the Privacy Shield, to a third party acting as a controller, we will do so consistent with any notice provided to data subjects and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the personal data for limited and specific purposes consistent with any consent provided by the data subjects; (ii) provide at least the same level of privacy protection as is required by the Principles and notify us if it makes a determination it cannot do so; and (iii) cease processing of the personal data or take other reasonable and appropriate steps to remediate if it makes such a determination. If Connexity has knowledge that a third party acting as a controller is processing such personal data in a way that is contrary to the Principles, Connexity will take reasonable steps to prevent or stop such processing.
With respect to our third-party agents, we will transfer only the personal data needed for an agent to deliver to Connexity the requested product or service. Furthermore, we will (i) permit the agent to process such personal data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal data transferred in a manner consistent with Connexity’s obligations under the Principles; and (iv) require the agent to notify Connexity if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.
Connexity remains liable under the Principles if an agent processes personal data received from EU member countries, in reliance on the Privacy Shield, in a manner inconsistent with the Principles, except where Connexity is not responsible for the event giving rise to the damage.
If you are located in the European Union, in the event that you wish to make a complaint about how your personal data is being processed by us or that we have not taken any action requested by you in relation to your rights set out above, you have the right to lodge a complaint directly with our EU supervisory authority and our data protection representative. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.
The details for each of these contacts are:
Data Protection Representative
|Contact:||Information Commissioner’s Office||Attn: Data Protection Representative|
|Postal address:||Wycliffe House
Cheshire SK9 5AF
Connexity UK Limited
London WC2B 6NHGermany
Connexity Europe GmbH
76139 KarlsruheUnited States
2120 Colorado Ave., Suite 400
Santa Monica, CA 90404
|Email enquiries:||firstname.lastname@example.orgemail@example.com or
EU individuals may direct any inquiries or complaints regarding our Privacy Shield compliance to Connexity’s Data Protection Representative contact above. Connexity will respond within 45 days. If you have an unresolved concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge), the International Centre for Dispute Resolution/American Arbitration Association, at http://go.adr.org/privacyshield.html. Finally, as a last resort and in limited situations, you may have the possibility to engage in binding arbitration through the Privacy Shield Panel. Connexity’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
- Processing your data outside the EEA
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