If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
This GDPR Privacy Notice uses the term “Service” to mean (1) the Company’s provision of marketing and sales information, and (2) the provision of trial access to the Company’s platform prior to the execution of a legal agreement.
For this GDPR Privacy Notice we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. IDM Global, Inc. (“Company”) will be the controller of your Personal Data processed in connection with the Services.
Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
What Personal Data Do We Collect From You?
We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
- First and last name
- Company Name
- Mailing address
- Email address
- Telephone number
Information we automatically collect when you use our Services: Some Personal Data may be automatically collected when you use our Services, such as the following:
- IP address
- Device identifiers
- Web browser information
- Page view statistics
- Browsing history
- Usage information
- Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.)
- Location information (e.g. IP address)
- Log data (e.g. access times, hardware and software information)
Additionally should you or your company sign a Masters Service Agreement with us we may collect further information from you in order to fulfill our regulatory requirements and/or to collect payment.
How Do We Use Your Personal Data?
We process Personal Data to personalize our communications. For example, we use Personal Data to:
- Create and manage user profiles
- Communicate with you about the Services
- Contact you about Service announcements, updates or offers
- Personalize website content and communications based on your preferences
- Meet contract or legal obligations
- Respond to user inquiries
- Fulfill user requests
- Enforce our Terms of Service
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
- First and last name
- Company Name
- Mailing address
- Email address
- Telephone number
Examples of these legitimate interests include:
- Operation and improvement of our business, products and services
- Marketing of our products and services
- Provision of customer support
- Protection from fraud or security threats
- Compliance with legal obligations
- Completion of corporate transactions
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
How and With Whom Do We Share Your Data?
- Analytics service providers
- Staff augmentation and contract personnel
- Hosting service providers
- Co-location service providers
- Telecommunications service providers
We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).
We also share Personal Data when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
- Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
- Maintain the security of our products and services
Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
How Long Do We Retain Your Personal Data?
We retain Personal Data about as long as:
- You desire to continue to receive information about IDM Global, Inc. and the Service that it provides
In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.
What Security Measures Do We Use?
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. For example, we maintain data in limited access servers and use encryption whenever possible.
Personal Data of Children:
We do not knowingly collect or solicit Personal Data from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us Personal Data, please contact us at [email protected]
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected] Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Company and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Company in the U.S. and will be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to EU-US Privacy Shield Framework, the details of which are further set forth below.
Company has certified to the EU.-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. For more information about the Privacy Shield Program, and to view Company’s certification, please visit www.privacyshield.gov. Company is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Company’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Please contact us at [email protected] with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through the American Arbitration Association, an alternative dispute resolution provider located in the United States. You can visit http://go.adr.org/privacyshield.html for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.
What If You Have Questions Regarding Your Personal Data?
If you have any questions about this GDPR Privacy Notice or our data practices generally, please contact us using the following information:
Name: IDM Global, Inc.
550 College Ave
Email address for contact:
Designated representative and contact information:
Data Protection Officer and contact information:
Data Protection Officer