“Special Category Data” means personal data about a person’s race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life, or sexual orientation.
“Processing” covers all activities relating to the use of personal data by us, from our collection through to our storage and disposal and every phase in between.
COLLECTION, USE, AND RETENTION OF PERSONAL DATA
We gather information on our users by tracking pages visited and collecting information from voluntary submissions. We may use various technologies as well (e.g., cookies) to collect information from your computer and about your activities on this Website. We collect aggregate information regarding which pages of this Website users access or visit.
We do not process any Special Category Data about you unless required to do so by law, such as in the event of a court case. However, some services require the disclosure of personal data.
Categories of Data We Collect
We may collect the following categories of data about you:
Name and Contact Information.
We may collect personal data including your name, organization, email, and mailing address in order to provide you with products or services or to communicate with you for other purposes.
Social Media Content.
This Website may include community discussions and areas for comments. Any content you provide on these channels will be considered “public” and is not subject to privacy protections. By submitting your comments in those areas, you give us permission to use those comments for any of our business purposes.
We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal data. You are not under any obligation to provide this information to us. However, if you withhold requested information, we may not be able to provide certain services to you.
Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your data to assess your qualifications.
We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us using the information below.
USES OF PERSONAL DATA
· To provide our services, products, and features to you; · To manage this Website; · To measure and improve our services, products, and features; · To develop internal and external analyses; · To contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account; · To facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements; · To administer, operate, facilitate, and manage your relationship and/or account with us. This may include sharing such information internally, as well as disclosing it to our affiliates or other · third parties; · To protect our users and provide them with customer support; · To provide you with news, special offers, marketing and promotional materials and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or inquired about or otherwise might be interested in, unless you have opted not to receive such information; · To audit downloads of information from this Website and also make follow-up contact with you by email in relation to the material you have accessed; and · Other purposes you consent to, are notified of, or are disclosed when you provide personal data.
AUTOMATIC DATA COLLECTION AND TRACKING
We also collect certain passive tracking data concerning how this Website is accessed and used (“Usage Data”). This Usage Data includes information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Website that you visit, the times and dates of your visits, the time spent on those pages, and diagnostic data.
A cookie is a text file sent by a web server and placed on your computer by your web browser. Cookies can be divided into two different types: “session” and “persistent.” Session cookies differ from persistent cookies primarily in that session cookies are temporary and expire and are normally deleted when you close your browser. Persistent cookies, in contrast, remain stored on your computer after you close your browser until they are deleted either because they expire, or you delete them. We use session cookies and persistent cookies in connection with providing this Website. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to access or use some portions of this Website.
Cookies are often used in conjunction with other Internet technologies, such as web beacons, to understand behavior on the Internet. “Local shared objects,” “LSO’s,” or “flash cookies” are data files similar to cookies, except that they can store more complex data, particularly for video, interactive gaming, and other similar services. “Web beacons,” “clear pixels,” “clear GIFs,” or “pixel tags” are small graphic images on a webpage or in an email. A “web server log” is a record of activity created by the computer that delivers the webpages you request to your browser. A “widget” is a program or application that can be embedded in a web page or mobile application and can provide real-time information, such as stock quotes or weather reports, or take information, such as online orders.
The types of cookies and other tracking technologies we may use are:
We may use session cookies to operate this Website and for security purposes.
We may use persistent cookies to remember your preferences and various settings.
Local Shared Objects.
We may use local shared objects to remember your settings, preferences, and usage.
We may use web beacons for things such as recording the pages and advertisements clicked on by users or tracking the performance of email marketing campaigns.
Web Server Logs.
We may use web server logs for things such as recording information about your browser (such as your IP address), the search term you entered or link you clicked to bring you to this Website, or tracking the performance of email marketing campaigns.
We may use widgets to allow third parties to collect data about users viewing this Website or interacting with that widget, possibly subject to privacy policies other than this one. In general, our purposes for using the above technologies are:
Your Preferences and User Experience.
Testing, Usability, and Performance.
We may use third-party Website Providers to monitor and analyze the use of this Website.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/.
• HubSpot Analytics HubSpot Analytics is a web analytics service offered by HubSpot, Inc. HubSpot utilizes cookie and usage data collected to track and examine the use of this Website, analyze demographic information, and to prepare reports on user activities and share them with other HubSpot
• LinkedIn Analytics
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu, https://youra dchoices.ca/choices/, and www.aboutads.info/choices/.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes
“Do Not Track” Signals
We do not track customers over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked.
Retention of Personal Data
Disclosure and Transfer of Personal Data
Except as set forth in this Policy, we will not disclose, share or sell your personal data. Personal data may occasionally be transferred to our affiliates and to third parties who act for or on behalf of us or in connection with our business, for our administrative purpose including activities such as IT management, for them to provide services to you, or to support and supplement the Services we provide. Such third parties may operate under different privacy policies. We may disclose the personal data collected (i) where disclosure is necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority; (ii) where disclosure would potentially mitigate our liability in an actual or potential lawsuit; (iii) where disclosure is otherwise necessary to protect our rights or property; (iv) where disclosure is necessary to protect the legal rights or property of others, including to protect the confidentiality or security of your personal data; (v) as part of a bankruptcy, merger, reorganization, or a sale of assets of us, our subsidiary, or division; (vi) where disclosure is necessary in connection with other business purposes including, without limitation, customer care, service quality, business management and operation, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences, and trends and dispute resolution; (vii) where disclosure is necessary for us to provide it to our attorneys, accountants, regulators, auditors or other advisors; or (viii) where it is otherwise necessary for us to disclose it as required or permitted by law.
International Transfers of Data. We are located in the United States. Please note that by using this Website, you give us your express and informed consent to transfer the data that you provide to us out of your country of residence to the United States, and to process it in the United States.
By providing us with your personal data, you consent to this transfer to the U.S., which your country may not consider as providing adequate privacy protections. You may withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent prior to its withdrawal. You may request more information about the safeguards that we have in place with respect to transfers of personal data by sending an email to email@example.com from the email address associated with your account.
YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA
You may have the following rights under applicable laws:
Right to Access Information
You may have the right to request access to personal data that we have collected about you. For instructions on accessing your information, please send an email to firstname.lastname@example.org from the email address associated with your account.
Right of Rectification or Correction
You may have the right to have your personal data rectified or corrected if that personal data is inaccurate or incomplete. Users are able to edit and update most of their personal data held by us on this Website, and if you have any queries or complaints, we encourage you to contact us at email@example.com. Alternatively, if you do not wish to do this you may make a formal request to have us rectify any inaccurate personal data on your behalf.
Rights of Objection and Restriction
You may have the right to object to or restrict the processing of your personal data under certain circumstances, including if we have no legitimate reasons to do so and in connection to direct marketing. If you have any queries or complaints about how we process your personal data, we encourage you to contact us at firstname.lastname@example.org . Alternatively, if you do not wish to do this you may make a formal objection or request to restrict the processing of your personal data by us.
Right of Data Portability
You have the right to be provided with a copy of the information we have on you in a structured, machine- readable and commonly used format (or have this transferred to a third party). Users are able to access most of their personal data held by us on this Website, and if you have any queries or complaints, we encourage you to contact us at email@example.com . Alternatively, you may make a formal request to access your personal data held by us. We will provide your personal data to you in a portable format to allow it to be transmitted to third parties.
Right of Deletion, Anonymization, or Blocking
You have the right to request that we delete, anonymize, or block your personal data under certain conditions, such as when processing is based on your consent or when processing is unnecessary, excessive, or noncompliant. Users are able to access most of their personal data held by us on this Website, and if you have any queries or complaints, we encourage you to contact us at firstname.lastname@example.org . Alternatively, if you do not wish to do this, you may make a formal request to delete, anonymize, or block your personal data held by us. Once your request has been confirmed, we will initiate the necessary steps to execute this procedure.
Withdraw Your Consent
You may have the right to withdraw your consent to our processing of your personal data. If you refrain from providing personal data or withdraw your consent to processing, some features of our Services may not be available.
Under data protection legislation, an individual may have various other rights, such as the right to be informed about third parties with which your personal data has been shared and the right to request the review of decisions taken exclusively based on automated processing that could affect your rights. You also have the right to complain to a data protection authority about our collection and use of your personal data.
Such rights of rectification, objection, restriction, access, portability, and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point at which we confirm your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by us and only imposed to the extent permitted by applicable law.
Exercise Your Rights
To exercise the rights listed above:
· Send an email to email@example.com from the email address associated with your account · Mail your written request to Attn: Legal Department, HyAxiom, Inc., 101 East River Drive, East Hartford, CT 06018.
You have certain choices about your personal data. Where you have consented to the processing of your personal data, you may withdraw that consent at any time and prevent further processing by contacting us as described above. Even if you opt out, we may still collect and use non- personal data regarding your activities on this Website and for other legal purposes as described above.
Email and Telephone Communications
We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
LINKS TO OTHER SITES
The security of your personal data is important to us. We follow generally accepted industry standards to safeguard personal data, including physical, technical, and administrative measures to protect the information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use generally acceptable means to protect your information, we cannot guarantee its absolute security. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure. By using our Services or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on this Website, by mail or by sending an email to you.
CHILDREN UNDER THE AGE OF 13
This Website is intended for a general audience, and we do not knowingly collect information about children or sell products or services to children. Consistent with the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly collect personal data from anyone under the age of 13. If you are under the age of 13, you must ask your parent or guardian to assist you in using this Website. If you are a parent or guardian and you are aware that your child has provided us with personal data, please email us at <href="mailto:firstname.lastname@example.org">email@example.com. If we become aware that we have collected personal data from children without verification of parental consent, we will take steps to remove that information from our servers.
SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE
This Supplemental California Privacy Notice only applies to our processing of personal data that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal data we have collected about them and whether we disclosed that personal data for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:
Category of Personal Data Collected by HyAxiom
Category of Third Parties To Whom Data is Disclosed for a Business Purpose
· Data analytics providers A real name, unique personal identifier, Internet Protocol address, · email address, or other similar identifiers. Service providers · Affiliates
Personal data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, address, telephone number. Personal data does not include publicly available information that is lawfully made · available to the general public from federal, state, or local government records. Note: Some personal data included in this category may overlap with other categories.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity
· Data analytics providers Serviceproviders · Affiliates · Data analytics providers · Service providers · Affiliates · Data analytics providers Browsing history, search history, information on a consumer’s · interaction with an internet website, application, or advertisement. Geolocation data Physical location or movements. Service providers · Affiliates · Data analytics providers · Service providers · Affiliates
Category of Personal Data Collected by HyAxiom
Professional or employment-related information
Current or past job history or performance evaluations.
Inferences drawn from other personal data to create a profile about a consumer
Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Sources of the Personal Information We Collect
Category of Third Parties To Whom Data is Disclosed for a Business Purpose
· Service providers · Affiliates · Data analytics providers · Service providers · Affiliates We may collect personal information used in relation to this Website from the following sources: · Directly from you; · From third parties acting on your behalf; or · From first and third party cookies that help us operate and assess this Website.
“Sales” of Personal Data under the CCPA
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us
for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal data. You may also make a verifiable consumer request on behalf of your minor child.
An authorized agent must provide a power of attorney or written permission, signed by you, when submitting a verifiable consumer request on your behalf. We may require you to verify your identity directly with us and confirm you provided the authorized agent permission to submit the request.
Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative, which may include your name, email address, phone number, or other personal data associated with your account.
If you are a California resident and would like to exercise any of your rights under the CCPA, please: Send an email to firstname.lastname@example.org from the email address associated with your account Mail your written request to Attn: Compliance, HyAxiom, 101 East Drive, East Hartford, CT 06018. We will process such requests in accordance with applicable laws.
California Shine the Light
Under California Civil Code sections 1798.83-1798.84, California customers are entitled to annually request and obtain information free of charge about what categories of personal data we shared with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes in the preceding calendar year. That notice will identify the categories of personal data shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please email us at email@example.com from the email address associated with your account to ensure a timely response to your request. firstname.lastname@example.org FOR EUROPEAN USERS
If you are located in the European Economic Area (EEA), Switzerland or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal data violates applicable law.
If you are located in the EEA, Switzerland, or United Kingdom, we will only transfer your personal data if: The country to which the personal data will be transferred has been granted a European Commission adequacy decision; or We have put in place appropriate safeguards with respect to the transfer and security of your personal data, for example through EU standard contractual clauses with the recipient, or the recipient is a party to binding corporate rules.
The Legal Basis on Which HyAxiom Collects Your Personal Data
Right to Object: You have a right to object to the processing of your personal data where that processing is carried out for our legitimate interest or for direct marketing.
Performance of a Contract Most of the processing of personal data by us is performed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at your request prior to entering such an agreement. Please be aware that, in certain circumstances, where you do not provide personal data which is required by us, we will not be able to provide the products and services under our contract with you or may not be able to comply with a legal obligation on us. You will be made aware if this situation arises and informed of what the consequences of not providing the personal data will be.
A second ground relied upon by us for other types of processing of your personal data is that it is necessary for the purposes of legitimate interests pursued by us. Such legitimate interests will include those in which we send you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is strictly necessary for fraud detection and prevention. We will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products, and features to you.
Compliance with a Legal Obligation
A third ground relied upon for certain types of processing is that it is necessary in order to allow us to comply with a legal obligation. We will disclose your personal data in the good faith belief that such action is necessary to:
· Comply with a legal obligation; · Protect and defend our rights or property; · Prevent or investigate possible wrongdoing in connection with this Website; · Protect the personal safety of users of this Website or the public; or · Protect against legal liability.