Updated 20th May 2020
If you'd like to unsubscribe, access, amend or delete any information, please contact firstname.lastname@example.org
If at any time you are concerned or have questions about how we might be handling your data, please reach out to our Data Protection Officer at email@example.com
TABLE OF CONTENTS
We will collect, store, use and disclose Personal Data (Personal Information) in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, UK Data Protection Act 2018, The California Consumer Privacy Act ("CCPA") as amended or superseded from time to time, and any national implementing legislation ("Data Protection Laws").
For the purpose of Data Protection Laws, in relation to any Personal Data you or any Users submit to our platform, you will be the data controller, and we will be a data processor of such Personal Data.
We adhere to the principles relating to the processing of Privacy & Personal Data.
We collect, process, and share Personal Data fairly and lawfully and for specified purposes. The law restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent processing, but ensure that we process Personal Data fairly and without adversely affecting the Data Subject.
We provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere.
We provide the Data Subject with all the information required by the law, including the identity of the Data Controller and Data Protection Officer, how and why we will use, process, disclose, protect and retain that Personal Data.
We check that the Personal Data was collected by the third party in accordance with the law and on the basis that contemplates our proposed processing of that Personal Data.
We collect Personal Data only for specified, explicit and legitimate purposes.
We do not use Personal Data for new, different, or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes, and they have consented where necessary.
We collect Personal Data only for specified, explicit, and legitimate purposes. We do not further process in any manner incompatible with those purposes.
We do not use Personal Data for new, different, or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes, and they have Consented where necessary.
We ensure that Personal Data is accurate and, where necessary, kept up to date. We correct or delete it without delay when inaccurate.
We store Personal Data only for specified, explicit, and legitimate purposes. They're not further processed in any manner incompatible with those purposes.
We secure Personal Data by appropriate technical and organizational methods or measures against unauthorized or unlawful processing and accidental loss, alteration, destruction, or damage.
We implement appropriate technical and organizational methods or measures in an effective manner to ensure compliance with data protection principles, according to commonly accepted standards, laws, or internal regulations.
We are able to demonstrate compliance with the data protection principles. We recognize new laws and regulations and adapt our activities to changes in the context or broad -range framework or business environment.
We have adequate resources and controls in place to ensure and to document the law compliance including:
We keep and maintain accurate records reflecting our processing, including records of Data Subjects' Consent and procedures for obtaining Consent. These records include, at a minimum, contact details of the Data Controller and the Data Protection Officer, descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data's retention period and a description of the security measures in place.
We ensure that all personnel have undergone adequate training to enable them to comply with data privacy laws. We regularly test our systems and processes to assess compliance with all of the regulations.
We do not share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place. We share the Personal Data internally if the recipient has a job-related need to know the information.
"Personal Data" means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We may obtain and use the following Personal Data and Sensitive Data about you and anyone you chose to add to our platform:
We do not intentionally collect data which is, by its nature, particularly sensitive (e.g., genetic data, biometric data, data revealing racial or ethnic origin, political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, criminal background or trade union membership). All responsibility for providing data as above does not belong to GAT. Providing such data by our partners and other third parties or their processing in our services or infrastructure is considered unintentional, and we exclude all legal liability.
You represent and warrant that you:
To process test services, you could obtain Testers Personal Data and potentially Sensitive Personal Data. For processing Sensitive Personal Data, the data subject has to give you explicit consent to the processing of those Personal Data for one or more specified purposes. Regardless of the legal or factual relationship between two independent entities, GAT disclaims its liability for any non-compliance of standards, law, or GDPR resulting from a violation by independent entities. GAT reserves that it is not a participant in the relationship regarding the consent to the processing of sensitive data by either party. Nor shall it be liable for negligence, disclosures, or infringements even if they were caused by unintentional negligence in implementing GAT infrastructure security mechanisms, enabling the provision of data processing services. In this regard, you must carefully read our Policy, understand it, accept it, and follow the rules.
You agree to indemnify us for any claims made by any data subjects arising from any unauthorized access or accidental loss, damage, corruption, or disclosure of Client Data arising from or in connection with your and/or our use or disclosure of data. You are strongly required to have appropriate recognition, orientation, and knowledge of the law if your professional activities are related to the processing of Personal Data or Sensitive Data that may violate someone's rights, regulations, standards, good and reasonable practices, or personal/human rights. In case of any doubts or hesitations, you must contact us and clarify them.
Cookies and IP Addresses
We may obtain information about your and your Users' device, which includes your and your Users' public IP address, browser type, and operating system where available. This accumulation of data is used to assist system administration.
We may also collect information regarding your or your Users' browsing activity and interests through the use of a cookie file. This cookie file is stored on the hard drive of your or your Users' device and contains information that is transferred to your or your Users' computer's hard drive. We use the collection of this data to help us improve the experience of users on our Website and Service, and to deliver a more personalized service with more relevant content. The collection of this data allows us to:
We use the following cookies:
You can find more information about some of the individual cookies we use and the purposes for which we use them below. Example of cookies used by the Service:
We use the services of many providers of data analysis solutions, below we indicate the most important ones.
Social Media And Advertising Cookies
e.g. Facebook / LinkedIn / Twitter
We use Facebook and LinkedIn's 3rd-party audience data such as age, gender, and interests to better understanding the behavior of our customers and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. For example, you may see certain ads on this Website or other websites because we contract with Facebook and other similar companies to target our ads based on information they or we have collected, including information that was collected through automated means (such as cookies and web beacons). These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.
Google Analytics / AdWords / Security
We use Google Analytics' / Adwords' 3rd-party audience data such as age, gender, and interests to better understanding the behavior of our customers and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. For example, you may see certain ads on this Website or other websites because we contract with Google and other similar companies to target our ads based on information they or we have collected, including information that was collected through automated means (such as cookies and web beacons). These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.
You may opt-out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/
We use Auth0 service for authentication users into the GAT Platform. https://auth0.com/privacy
We care about the safety and privacy of children online. Our Website and services are not designed or directed at children. We do not intentionally collect any personal information from persons under the age of 16 years of age. If we become aware that we have inadvertently received personal information from a user under the age of 16, we will delete the information from our records according to the law (e.g., GDPR, CCPA, or Children's Online Privacy Protection Act of 1998 ("COPPA"). If any of the laws is more severe, we will comply with it.
The rules for the processing of Personal Data, protection of privacy and freedom for private persons are clear to us, known and communicated to all our employees. We use information for ethical and legitimate purposes, legal and responsible business conduct.
The Personal Data we hold about you and your Users may be used in any of the following ways:
We may also use your Personal Data to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use Personal Data for these purposes when it is necessary to protect, exercise, or defend our legal rights, or when we are required to do so by applicable law.
Staff members operating within the EEA who work for or on behalf of us may process this information. Such staff members may, among other things, be involved in the processing of payment details, the provision of support services, and the delivery of your and your Users' request(s) for us to provide the Service.
Without limiting the foregoing, you agree that Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be processed by our service providers based in countries outside of the EEA for the purposes of providing you with the Service. Such countries may not have laws offering the same level of protection for Personal Data as those inside the EEA.
We store the Personal Data you and your Users provide us with on our secure servers. In the event of us giving you or your Users (or you/they choosing) a password that grants you/them access to specific areas within our Website or Service, it remains your/their responsibility to maintain the confidentiality of this password. This includes the obligation to refrain from sharing your/their password with other parties. As the transmission of data via the Internet cannot be assumed completely secure, we cannot guarantee the security of any of your or your Users' data transmitted to our Website or Service; you are therefore responsible for any risk associated with such transmission. We will however at all times take all reasonable steps to ensure the transmission of your and your Users' data is executed as securely as possible, and upon receipt of your/their data, we will continue at all times to enforce strict security procedures and features in an attempt to prevent any unauthorized access.
Disclosure of your and your Users' Personal Data (including, without limitation, Client Data) to third parties will only occur in any of the following events:
We are required to disclose your or your Users' Personal Data in order to fulfill any legal obligation, to enforce our terms and conditions, or to protect the property, rights, or safety of GAT, users of our services, or others. In such a case, information may be exchanged with third-party companies or organizations in order to prevent fraud or reduce credit risk.
You acknowledge and agree that we may also disclose Personal Data (including, without limitation, Client Data) with:
Our service providers have to follow our express instructions when processing the Personal Data you or your Users provide and must have in place appropriate technical and organizational security measures to safeguard such Personal Data, and we do not allow them to use this information for their own commercial purposes.
If we do not process your Personal Data in accordance with our legitimate interest or based on a contractual obligation we have with you, we may share or disclose your Personal Data if you provide us with your affirmative consent.
We share the Personal Data we hold with third parties, according our internal Supplier Security Policy and supplier security and privacy risk assessment, such as our service providers if:
You may email us at firstname.lastname@example.org to request a copy of the Personal Data we currently contain.
You can correct what Personal Data We currently contain by emailing us at email@example.com.. to request that we correct or rectify any Personal Data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
If you should wish to cease use of our services and have your Personal Data deleted, then you may submit a request by emailing us at firstname.lastname@example.org. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your Personal Data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.
At any time, you may withdraw your consent to our processing of your Personal Data through our Websites by notifying us via email at email@example.com Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your Personal Data. Where applicable, we will ensure such changes are shared with trusted third parties.
You can exercise any of your rights by contacting via email to firstname.lastname@example.org.
We may need to request specific information from you to reasonably confirm your identity and verify you are the Person Data belong to. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request and to exercise your rights.
You will not have to pay a fee to access your Personal Data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Whenever we use a processor, there must be a written contract in place. If a processor uses another organization (i.e., a sub-processor) to assist in its processing of Personal Data for a controller, it needs to have a written contract in place with that sub-processor.
What we set up in the contract:
What is our documentation of processing activities:
If we process special category we document:
When preparing to document our processing activities we:
As part of our record of processing activities we document, or link to documentation, on:
We document our processing activities in a granular way with important links between the different pieces of information.
We conduct regular reviews of the Personal Data we process and update our documentation accordingly.
We document our processing activities in writing and electronic form so we can add, remove, and amend information easily.
We share the results of processing your data, but we do not provide the above documents.
We consider data protection issues as part of the design and implementation of systems, services, products, and business practices.
We make data protection an essential component of the core functionality of our processing systems and services.
We anticipate risks and privacy-invasive events before they occur and take steps to prevent harm to individuals.
We only process the Personal Data that we need for our purposes(s) and that we only use the data for those purposes.
We ensure that Personal Data is automatically protected in any our IT system, Service, product, and/or business practice so that individuals should not have to take any specific action to protect their privacy.
We provide contact information of those responsible for data protection both within our organization and to individuals.
We offer strong privacy defaults and controls.
We only use data processors that provide sufficient guarantees of their technical and organizational measures for data protection by design.
When we use other systems, services, or products in our processing activities, we make sure that we only use those whose designers and manufacturers take data protection issues into account.
Our information security & privacy risk assessment and Data Protection Impact Assessments (DPIA) process is based on international standards and best practices.
We have appointed a Data Protection Officer (DPO) based on their professional qualities and expert knowledge of data protection law and practices.
Our DPO reports directly to our highest level of management and is given the required independence to perform their tasks.
We involve our DPO, in a timely manner, in all issues relating to the protection of Personal Data.
We ensure that any other tasks or duties we assign our DPO do not result in a conflict of interest with their role as a DPO.
Our DPO is tasked with monitoring compliance with the GDPR and other data protection laws, our data protection policies, awareness-raising, training, and audits.
We take account of our DPO's advice and the information they provide on our data protection obligations.
When carrying out a DPIA, we seek the advice of our DPO, who also monitors the process.
When performing their tasks, our DPO has due regard to the risk associated with processing operations and takes into account the nature, scope, context, and purposes of the processing.
Our DPO is easily accessible as a single point of contact for our employees, individuals, partners, contractors, third parties and the regulator.
We develop, implement and maintain Information Security & Privacy Management System aligned with ISO 27001 standards and safeguards appropriate to our size, scope, and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Anonymization where applicable). We regularly evaluate and test the effectiveness of those safeguards to ensure the security of our processing of Personal Data. We exercise particular care in protecting Sensitive Personal Data from loss and unauthorized access, use, or disclosure.
We maintain data security by protecting the confidentiality, integrity, and availability of the Personal Data, defined as follows:
We comply with and not attempt to circumvent the administrative, physical, and technical safeguards we implement and maintain in accordance with the law and relevant standards to protect Personal Data.
We have put in place procedures to deal with any suspected security incident and Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.
If you know or suspect that a security incident or Personal Data Breach has occurred immediately, contact via email to email@example.com. You should preserve all evidence relating to the potential security incident and Personal Data Breach.
Information we collect from you will be processed in EEA and could be processed outside EEA, depending on the purpose of processing. Whenever Personal Data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
You could check how the EU determines if a non-EU country has an appropriate level of data protection by clicking the link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en .
You could check the commercial sector: EU-US Privacy Shield by clicking the link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_en .
If Personal Data is transferred outside the EU for doing business by GAT in other law jurisdictions, then EU law and law of the relevant jurisdiction apply jointly. If they are divergent, that stringent are used.
We may, at times, provide links on our Website to third party websites, including without limitation those owned or managed by our partner networks, affiliates, or advertisers. These websites have separate privacy policies, and we, therefore, cannot accept any responsibility for the content. As such, choosing to follow these links is a choice you make at your own risk, and we advise that you check these websites' individual privacy policies before submitting any Personal Data.
If you are a California resident, you have the right to request that we disclose what information we have collected, used, disclosed, or sold over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you, based on your specific request:
If we disclosed your personal information for a business purpose, the personal information categories that each category of recipients obtained. If we sell your personal information for a business purpose, the personal information categories that each category of recipients purchased.
If you are California resident, you have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete your personal information from our records, and direct our service providers to do the same, unless an exception applies.
If you are California resident and have 16 years old or more, you have the right to direct businesses that sell personal information to not sell your personal information.
We do not intentionally process personal information children under 16 years old.
Under the CCPA, if you are California resident between 13 and 15 years old, you must affirmatively authorize the sale of your personal information or personal information. If the child is under the age of 13 years old, a parent or guardian must affirmatively authorize the sale of information. If you opt-in to personal information, sales may opt-out of future sales at any time.
We will not discriminate against you for exercising any of your CCPA rights.
We do not offer financial incentives permitted by the CCPA.
Under the CCPA, if you are California resident, we could offer you certain financial incentives permitted by the CCPA, or different prices, rates, levels, or quality of goods or services that are reasonably related to your personal information's value to the business.
If you are a California resident, you can exercise the right to know/right to access information. You or your authorized agent may submit a verifiable request via email firstname.lastname@example.org.
You may only make a verifiable request to know or request for access twice within a 12-month period. The verifiable request must include information that allows us to reasonably verify you are the person about whom we collect personal information or an authorized representative and describe your request in enough detail that we can properly understand, evaluate, and respond to it.
If we are able to verify your request, we will make our best effort to respond within forty-five (45) days of our receipt of your request. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We will not disclose information to you if we cannot verify your identity.
You will not have to pay a fee to access your Personal Data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
If you are a California resident, you can exercise the right to request deletion. You or your authorized agent may submit a verifiable request via email email@example.com.
If we are able to verify your request, we will make our best effort to respond within forty-five (45) days of our receipt of your request. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. In our response, we will specify the manner in which we have deleted your personal information. We will not delete information if we cannot verify your identity.
For California residents to exercise the right to opt-out if we engage in selling your personal information, you or your authorized agent may submit a request via email firstname.lastname@example.org.
We will act upon your request to opt-out within 30. (thirty) days of receiving the request. We will instruct the third parties to whom the information has been sold in the 30 days prior to your request not to further sell the information, and we will notify you when this instruction has been completed.
We will not act upon a request from authorized agents if the agent does not submit proof that the agent has been authorized by you to act on your behalf. We will not act upon a request if we believe it is fraudulent.
We will not respond to requests to know/requests for access or requests for deletion unless we can verify your identity to a reasonable degree of certainty. To verify your identity, when feasible, we will use information about you that we already have; however, we may need to request additional information, which we will use only for the purposes of verification. We may also use a third-party identity verification service. The information we need to verify your request will depend on the nature and scope of your request. Upon receipt of your request, we will notify you if we need additional information from you to verify your request.
We do not sell your personal information.
We conduct periodic, not less than every 12 months Policy and Information Security & Privacy System Management and documentation reviews. Review is mandatory after changes the nature, scope, context, or purposes of the processing Personal Data. In all of aspect, this Policy, the reviewer must demonstrate independence, knowledge, and experiences according to Personal Data protection.
We are updating the Policy every 12 months and anytime if there are any material changes to the nature, scope, context, or purposes of the processing.
If at any time we make a change to this Policy, we will update this page to reflect such change. If we make material changes to how we treat your Personal Data, we will notify you by email. Through a notice on this page, however, we recommend you review this page periodically to ensure you remain happy with the latest version.
The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you.
We are monitoring the current developments with regards to UK Brexit and regulations that may arise.
Right now, the UK is still subject to the EU's GDPR. The UK has its own version of the GDPR, the Data Protection Act 2018. There are no plans to repeal this law post-Brexit, but some changes are possible (link to actual https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/779335/Keeling_Schedule_for_GDPR.pdf
You could check Brexit and data privacy impact in The Information Commissioner's Office clicking the link: