This policy is effective as of 28 May 2018.
Protecting the personal privacy of every customer, vendor, and employee is a crucial part of gaining and keeping your trust in SofaDonDo Org. (the “Organization”, “we”, “us”). As a global organization, we strive to deploy consistent, rigorous policies and procedures to provide a high level of privacy protection across all of our businesses and services.
This Notice does not apply to third-party applications, products, services, websites or social media features that may be accessed through links that we provide on our websites and interfaces. Accessing those links may result in the collection of information about you by a third party. We do not control or endorse those third-party websites or their privacy practices. We encourage you to review the privacy policies of such third parties before interacting with them.
Your privacy is of utmost importance to us. We render our products and services to you on the basis of your understanding of your data privacy rights.
This Notice will be made multi-language, and all language versions shall be valid. In case of any discrepancy between the English version and other language versions, the English version shall prevail.
Please read this Notice carefully. When visiting our website and using our services that link to or reference this Notice, you agree to be bound by the terms and conditions of this Notice.
What is your personal data?
Personal data is any information that relates to an identifiable living individual. Any piece of data—whether by itself or used in conjunction with other pieces of data in a data controller’s possession—that can be used to identify you is considered your personal data. The processing of your personal data is governed by applicable privacy laws.
What role do we play in processing your personal data?
We are the data controller with respect to processing your data. This means that we decide how your personal data is processed and for what purposes. We know that you care about how your personal data is used and shared, and we appreciate your trust that we will do so carefully and sensibly. For more information, you can contact us using the channels set forth in the “Whom should I contact?” section of this Notice.
When do we collect your personal data?
We can collect some of your data:
whenever you become our customer;
whenever you register or log in to use our online services;
whenever you use our products and services;
whenever you fill in forms and contracts that we send you;
whenever you opt into our online or offline marketing activities, including but not limited to: newsletters, online and live event registrations, and other promotional information and materials;
whenever you contact us through our various channels.
Our collection of personal data
The personal data we collect includes any and all data you provide us with when you: enter into contract with us, register an account with us, update or add your account information, enter our website, fill out our web forms, or give us data in any other way.
You may choose not to provide us with any of your data, but that may hinder us from fully administering services to you if such services require your personal data. We use your personal data whenever we communicate with you, respond to your requests, manage your account, customize your service experience, improve our products and services, and personalize marketing activities. We may communicate with you through mail, email, or telephone. We will send you strictly service-related announcements or information on rare occasions, when it is necessary to do so.
Personal data we collect
When you register or log in to use our services, we may collect and store data including your name, phone number, address, email address, Internet Protocol (IP) address, login credentials, account name, and account activity.
We also receive and store certain types of data whenever you interact with us. For example, we use "cookies", which are unique identifiers that we transfer to your device to enable our systems to provide service features such as personalized advertisements on other websites, provide remote access for you, allow you to visit our website without re-entering your username and/or password, verify that you have the authorization needed for the services to process your requests, personalize and improve your experience, record your preferences, customize functionalities for your devices, and to improve the functionality and user-friendliness of our services. It also helps us to better understand how you interact with our services and to monitor aggregate usage and web traffic routing on our website. Most of the cookies we use are so-called "session cookies". Cookies do not cause any damage to your computer and do not contain any viruses. Most browsers automatically accept cookies as the default setting. You can modify your browser settings to reject our cookies or to prompt you before accepting a cookie. However, if a browser does not accept our cookies or if you reject a cookie, some portions of our services may not function properly.
We obtain certain types of data whenever your web browser accesses our website or advertisements and other content served by us or on our behalf on other websites. This data may include the IP address used to connect your computer to the internet, device ID or token, unique identifier, device type, ID for advertising, referral URL, computer and connection data such as the type of operating system you use, your device information, your software information, browser type, browser language and version, ad data, access times, your browsing history, and your web log information. Our server automatically receives and records the IP address your browser sends to our server when you login to our website. We will store your IP address in our user registration databases. We will use your IP address to provide the most appropriate contents based on your geographic area or information derived from your IP address.
Non-personal information we collect
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect your activities on our website, cloud services, software, and hardware. The information is anonymized before being stored in our servers. We aggregate and use this data to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest.
Our website keeps your account information active in our user registration databases in order to provide immediate access to your personal data each time you visit our website, as noted above.
Use of Google Analytics
Use of Fabric
Use of opt-in/subscription
You have a choice of whether or not you want to receive marketing communication materials from us, and how you want to receive these notifications. These materials detail marketing activities from us related to product solutions, services, and other helpful business content.
You can manage your preferences by:
opting into a newsletter subscription on a web form;
opting into marketing activities on a web form; or
unsubscribing from a newsletter or opting out of marketing activities, by clicking a link at the bottom of newsletter or emails regarding marketing activities.
If you no longer wish to receive these communications from us, please follow the opting out or “unsubscribe” instructions provided in the link at the bottom of our marketing communications emails, or update your account settings.
How do we process your personal data?
We comply with our obligations under applicable privacy laws by: keeping personal data up to date; storing and destroying it securely; collecting and retaining only the necessary data that we need to provide you with service; protecting personal data from loss, misuse, unauthorized access, and disclosure; ensuring that appropriate technical measures are in place to protect personal data.
The processing operations we perform on your data cover automated and non-automated means of collecting, recording, organizing, structuring, storing, altering, retrieving, using, transmitting, disseminating or otherwise making available, aligning or combining, restricting, and/or erasing your data.
We use your personal data for the following purposes:
To design and deliver our services and activities to you
To operate our website to provide you access to and use of our services
To inform you of online and offline offers, products, services, and updates
To customize, measure, and improve our services and our marketing communication activities
To provide services and products requested by you as described when we collect the information
To contact you to conduct research about your opinions of current services and products or of potential new services and products that we may offer
To send you communications regarding marketing activities or conduct webinars informing you of our news, events, new products, business tools and information, and activities
To share your contact details with our affiliate offices around the world within our group companies, for the purposes of internal administration and back-office support, to ensure our network security, and to prevent fraud
To maintain the integrity and safety of our data technology systems which store and process your personal data
To enforce or defend our policies or contract with you
To detect and investigate data breaches, illegal activities, and fraud
What is our lawful basis for processing your personal data?
In general, the lawful bases for us to process your personal data—for the various types of processing performed on your data—are, as applicable: processing as necessary for us to enter into and to perform our contract with you, or processing as necessary to pursue the legitimate interest of our Company or of the third parties. To know what types of processing your data undergoes, you can refer to “How do we process your personal data?” section of this Notice.
We will collect, process, and use the personal data supplied by you only for the purposes communicated to you and will not disclose your data to third parties except under the circumstances of data disclosure described in the “Sharing your personal data” section below.
Where we talk about our legitimate interest or that of third parties, such legitimate interest can include:
Implementation and operation of a group-wide organizational structure and group-wide information sharing;
Right to freedom of expression or information, including in the media and the arts;
Prevention of fraud, misuse of company IT systems, or money laundering;
Operation of a whistleblowing scheme;
Physical security, IT, and network security;
Internal investigations; and
Proposed mergers and acquisitions
Necessity to provide us data
You are not under any obligation to provide us any personal data. As noted below, the choice is yours. However, please note that without certain data from you, we may not be able to undertake some or all of our obligations to you under our service contract with you, or adequately provide you with our full range of services. If you would like to obtain more details about this, you can contact us using the channels set forth in the “Whom should I contact?” section of this Notice.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with the categories of data recipients listed below. We will only share your data with third parties outside of the Company with your consent, and you will have an opportunity to choose for us not to share your data.
We may disclose your personal data to:
our affiliated entities within our global group of companies worldwide to provide you services such as detecting and dealing with data breaches, illegal activities, and fraud, maintaining the integrity of our information technology systems, as well as other internal administration purposes.
third-party service providers whom we subcontract to work on our behalf or for us and therefore may have access to your data only for purposes of performing these tasks on our behalf and under obligations similar to those described in this Notice, who perform functions such as data processing, managing and enhancing customer data, providing customer service, conducting customer research or satisfaction surveys, marketing support, informational systems technical support, to help us provide, analyze, and improve our services such as data storage, maintenance services, database management, web analytics, improvement of our service features, and to assist us in detecting and dealing with data breaches, illegal activities, and fraud.
governments and/or government-affiliated institutions, courts, or law enforcement agencies to comply with our obligations under relevant laws and regulations, enforce or defend our policies or contract with you, respond to claims, or in response to a verified request relating to a government or criminal investigation or suspected fraud or illegal activity that may expose us, you, or any other of our customers to legal liability; provided that, if any law enforcement agency requests your data, we will attempt to redirect the law enforcement agency to request that data directly from you, and in such event, we may provide your basic contact information to the law enforcement agency.
third parties involved in a legal proceeding, if they provide us with a court order or substantially similar legal procedure requiring us to do so.
We will display your personal data and account activity in your profile page and elsewhere on our service portals according to the preferences you set in your account. You can review and revise your profile information at any time. Please consider carefully what information you disclose in your profile page and your desired level of anonymity. In your profile page, we will also display your device information as well as provide the network connection information for the devices to the applications that connect to your devices.
How long do we keep your personal data?
Privacy of data subjects under the age of 16
Our products and services are not targeted to persons under the age of 16. We do not knowingly collect or process personal data from persons under the age of 16. Please note that if you are under the age of 16, you should not buy or use our products or services, and we will not be liable for any losses or damages incurred by the unauthorized disclosure or processing of personal data under the age of 16.
Your rights and your personal data
Unless subject to an exemption under applicable privacy laws, you have the following rights with respect to your personal data:
The right to request a copy of your personal data which we hold about you.
The right to request that we correct any personal data that is found to be inaccurate or out of date.
The right to request that we erase your personal data where it is no longer necessary for us to retain such data, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims.
The right to withdraw your consent to the processing at any time, where we rely on your consent to process your data. This includes cases where you wish to opt out of marketing communications that you receive from us.
The right to request that we provide you with your data and, where possible, to transmit that data directly to another data controller, where the processing is based on your consent or is necessary for the performance of a contract with you, and, in either case, we process the data by automated means.
The right to restrict our processing of your personal data where you believe such data to be inaccurate, or our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
The right to object to us using your personal data, where the legal justification for our processing of your personal data is our legitimate interest. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of legal claims.
The right to lodge a complaint regarding our processing of your data, with the competent authority where you reside or in which your data is processed.
If you would like to exercise any of the above rights, please do so by contacting us: email@example.com
After receiving your request, we will evaluate your request and inform you how we intend to proceed with your request. Under certain circumstances, in accordance with applicable privacy laws and regulations, we may withhold access to your data, or decline to modify, erase, port, or restrict the processing of your data.
Please be advised that if you exercise the rights to erase data, restrict or object to our processing, or to withdraw your consent, we may not be able to continue providing our services to you if the necessary data is missing for processing.
Transfer, storage, and processing of data abroad
As noted in the “Sharing your personal data” section of this Notice, as a globally operating company, we may share your information with our affiliate companies or third parties. Please refer to the “Sharing your personal data” section of this Notice for the recipients of your data and the reasons for our provision of your data to them. Where such entities are located in other countries and jurisdictions, we will therefore be transferring your personal data outside of the European Economic Area. In making such data transfers, we make sure to protect your personal data by applying the level of security required by applicable privacy laws. Where we transfer your data to a country or jurisdiction that cannot guarantee the required level of protection as required by applicable privacy laws, we have enhanced our IT security measures and have entered into Standard Contractual Clauses (SCCs) with the transferee to require security obligations on the transferee, both of which are intended to increase the protection of your personal data. SCCs are one of a number of "appropriate safeguards" under the applicable privacy laws that enable the transfer of personal data concerning data subjects within the European Economic Area to jurisdictions that have not been designated by the European Commission as possessing an adequate level of data protection. You may request a copy of such SCCs from us, or inquire about transfers of your information, by providing your request to the contact window set forth in the “Whom should I contact?” section.
If we wish to use your personal data for a new purpose not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing such further processing for a new purpose. This new notice sets out the relevant new purpose and processing conditions. In such a case, we will find a lawful basis for further processing, and whenever necessary, we will seek your prior written consent to such further processing.
We protect your data using technical measures to minimize the risks of misuse, unauthorized access, unauthorized disclosure, loss or theft, and loss of access. Some of the safeguards we use are data pseudonymization, data encryption, firewalls, and data access authorization controls. We take our data security very seriously. Therefore the security mechanisms used to protect your data are checked and updated regularly to provide effective protection against abuse.
The servers through which we collect your information are usually encoded using the encryption module of your browser, and are certified by renowned institutions for international encryption technique. If necessary, we use Secure Sockets Layer (SSL) encryption to protect your personal information. Moreover, we have put in place additional and comprehensive state-of-the-art security measures every time your data are accessed through the internet. Firewalls prevent unauthorized access. Diverse encryption and identification layers protect your data from intrusion or disclosure to third parties during data transfer. Furthermore, we internally use sophisticated encoding methods in order to prevent decoding by unauthorized persons. Moreover, an electronic identifier is generated during data transfer to safeguard your information.
For your confidentiality and security, we use IDs and passwords to secure your personal information. It is important for you to protect your ID, password, or any personal information. Do not disclose your personal information, especially your password, to anyone. When you are finished using our services, please do not forget to log out from your account. If you share a computer, whether in a public or private setting, be sure to sign off and close your browsers when finished using a shared computer.
If you believe that the security of your data has been compromised, or if you would like more information on the measures we use to protect your data, you can contact us using the channels set forth in the “Whom should I contact?” section of this Notice.
What are your choices?
You have the choice to allow us to collect and process your data. The collection and processing of your personal data is neither a statutory nor a contractual requirement, although as noted above, we will be unable to provide you with certain services without the necessary data.
If you are dealing with us online, note that most browsers will inform you how to prevent your browser from accepting new cookies, how to receive notifications whenever you receive a new cookie, and how to disable cookies. Additionally, you can disable or delete the data used by browser add-ons, such as Flash cookies, on your browser or on the website of its manufacturer.
You can always choose not to provide us with your data. In case we may need such data to process your requests, we will inform you of our constraints.
To the extent that you have consented to our processing of your data, you can choose to discontinue our processing at any time.
You can choose to add or update data that you have provided us with.
You can choose to erase your data, or choose to restrict our processing of your data instead.
You can choose to port your data to a third party under the conditions stated above.
You can choose to object to our processing of your data.
You can inform us of your choices or request on any data processing aspect listed above using the channels set forth in the “Whom should I contact?” section of this Notice.
In summary, what we are allowed to do with your data—with limited exceptions under applicable privacy laws—is up to you. However, in the event that you choose not to let us further process your data, your choice may affect the delivery of our obligations or services to you. In this case, we will inform you of our constraints.
Whom should I contact?
If you have any questions about this Privacy Notice, or if you would like to exercise any of your rights, or if you have any complaints that you would like to discuss with us, please send us a signed and dated request. State your request clearly and accurately within the first sentence of your query. You may contact us through the following method:
contact us at: firstname.lastname@example.org
In case of disagreements relating to our processing of your personal data, you can submit a request for mediation or other administrative actions to the data protection supervisory authority with the competent authority where you reside or in which your data is processed. Please click here for a list of local data protection authorities in EEA countries: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.