Senzing Privacy Notice

Personal Information that We Collect and Purpose of Use

The following table describes what data is being collected through the Website, in what manner and for what purposes it may be processed:

In addition, we may process Personal Information collected via the Website:

• For any other purpose specified in this Privacy Notice and/or in our Terms of Use.
• To contact you as and when we believe it to be necessary for technical, administrative, or security reasons.
• To prevent, detect and fight fraud, security threats, or other illegal or unauthorized activities.
• To ensure legal compliance with legal requirements that apply to us and you.
• To ensure compliance with the Terms of Use that apply to us and you.
• For the purposes described under the sections titled “Sharing of Information with Third Parties” and “Cookies.”

Fields designated for mandatory completion are explicitly indicated. If you do not enter the requisite data in the mandatory fields, you will not be able to complete the relevant contact form. It is important that you understand there is no requirement by law for you to provide us with your personal details – the information you share with us is entirely voluntary, and you may avoid providing such information either by not filling in specific forms or by disabling cookies (please see more information on that in the Cookies section).

By providing any Personal Information to us you warrant and represent that the information you provide is complete, accurate, and correct. Your failure to do so will likely result in our being unable to contact you about your inquiries. It is your responsibility to update us if any of the information you provided is no longer correct or accurate and inform us of the required updates.

Our Legal Basis for Processing

We will only process your Personal Information on our own behalf where we have a legal basis to do so. The following are the legal bases under which we process your information in the manners specified above:

• As permitted by applicable law.
• Legal obligation – we may process your Personal Information as necessary to comply with the law (not including contractual obligations).
• Performance of a contract to which we and you are parties.
• Legitimate interests – we may use your Personal Information where we have legitimate interests to do so. For instance, we analyze users’ behavior on the Website to continuously improve it and we process information for administrative, fraud detection, and other legal purposes.
• Consent – where no other legal basis for processing applies, we may process your Personal Information based on your consent as you may be asked to provide from time to time.

Joint Controllership

Currently, we do not jointly determine the purposes and means of processing Personal Information with any third-party (a “joint controller”). If a joint controller situation is established in regard to your Personal Information, the essence of the legal arrangement between us and such other controller shall be made available to you upon request.

Sharing of Information with Third Parties

We do not, and currently do not intend to, sell any of your Personal Information to any third party. We will not transfer your personal details or any information collected pertaining to your activities on the Website (provided that such details and information identify you personally) to any third party, except in the following cases (or as otherwise outlined in this Privacy Notice):

• If we reasonably believe that you have breached the Terms of Use or performed any act or omission that we reasonably believe to be violating any applicable law, rules, or regulations, we may share your information with law enforcement and other competent authorities and with any third party that may consult with us or assist in connection with any such breach as may be required to handle any result of your wrongdoing including without limitation, in order to contain, remediate, prevent, investigate any such breach, and/or establish or exercise any of our legal rights.

Furthermore, your Personal Information may be disclosed:

• As permitted or required by, or in response to, lawful requests by applicable local law enforcement agencies or regulatory agencies, or agencies with responsibility to oversee and enforce national security.
• In any case of dispute, or legal proceeding of any kind between you and us, or between you and other users or third parties.
• In any case where we may reasonably believe that sharing information is necessary to prevent serious damage to you or to your property or to any third party or their property.
• If we organize the operation of the Website within a different framework, or through another legal structure or entity, or if we are acquired by, or merged with another entity, provided however, that those entities agree to be bound by the provisions of this Privacy Notice.
• To our service providers for the purpose of helping us execute certain tasks outsourced to them or providing capabilities we require. The service providers to which we provide Personal Information in connection with the Personal Information collected through the Website are: (1) email service providers for email campaign management and to send you emails on our behalf, with the express provision that their use of such information must comply with our instructions; and (2) billing, processing payments, marketing automation, our advertisements on social media, CRM platform, analytics tools providers, web page building tools, cloud services, and support and maintenance operation tools. Our service providers do not have any right to use your Personal Information collected from the Website beyond what is necessary for the purpose of facilitating their services for us and are subject to data protection agreements to the extent required under applicable law.
• In anonymous, statistical or aggregated information with companies or organizations connected to us, and with suppliers, business partners, advertisers, and every third party, according to our absolute discretion.

We collect this information for the purpose of providing the Website, identifying and communicating with you, responding to your requests/inquiries, servicing your purchase orders, and improving our services. We will keep your Personal Information for no longer than is necessary for the purposes for which it is processed. In terms of Personal Information we use for marketing, we will keep this data for as long as we are able to market to you and if you withdraw your consent or opt-out of marketing communications, we will keep your contact details only to ensure that we do not contact you again for marketing purpose

Log Data

Third-party services (such as Google Analytics and MailChimp) collect non-identifying information that your browser sends whenever you visit our Website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages and other statistics.

Log Data is not accessible, viewable or transmitted to us. We receive general user data which it uses to understand viewer demographics (general regions of visitors, age, gender, most popular pages, average time spent for viewer visits, etc.). These third-party service providers have their own privacy policies addressing how they use such information.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and transferred to your device. We use cookies to collect information in order to improve our services for you. We do not use first party cookies; that is, cookies that are set by us. We do use third party cookies (such as MailChimp) – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we may use cookies and other tracking technologies for the following purposes:

• Assisting you in navigation.
• Assisting in login and your ability to provide feedback.
• Analyzing your use of our products, services, or applications.
• Assisting with our promotional and marketing efforts (including behavioral advertising).
• Improving your experience on our website.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies, or to notify you when receiving a new cookie.

If you do not accept cookies, you may not be able to use some features of our website

California and Delaware “Do Not Track” Disclosures

California and Delaware law require us to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. We adhere to the standards set out in this Privacy Notice and do not monitor or respond to Do Not Track browser requests. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Service Providers

We may employ third-party companies and individuals to facilitate our Website, to provide the Website on our behalf, to perform Website-related services, and/or to assist us in analyzing how our Website is being used.

These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.

Communications

Upon your opt-in, we may use your Personal Information to contact you with newsletters, marketing or promotional materials, requests for information, and/or other information that may be of interest to you. You may opt out of these communications from us by following the unsubscribe links in such communications. Additionally, you can email support@senzing.com at any time to be removed from any communications.

Compliance with Laws

We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Website.

Security

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. We cannot guarantee that the Website is immune to unauthorized access to the information stored therein and to other information security risks.

Data Retention Policies

Subject to your right to deletion as required by law, we will retain your information for as long as is reasonably necessary to engage with you in relation to the interaction for which we collected your information or as otherwise permitted by applicable law. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

International Data Transfers

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the information, including Personal Information, to the United States and process it there.

Your consent to this Privacy Notice followed by your submission of such information represents your agreement to that transfer.

Links to Other Sites

Our Website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Notice of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

GDPR Disclosure

You may have the rights prescribed below in relation to Personal Information processed by us if you are a data subject in the EEA or your Personal Information is otherwise governed by the EU General Data Protection Regulation 2016/679 (“GDPR”):

• The right to be informed about how your Personal Information is being used.
• The right of access to your Personal Information processed by us, which includes the right to obtain confirmation as to whether or not Personal Information concerning you is being processed, and, where that is the case, access to the Personal Information and the purposes of the processing; categories of Personal Information concerned; recipients or categories of recipients to whom the Personal Information have been or will be disclosed; where possible, the envisaged period for which the Personal Information will be stored; the existence of the right to request rectification or erasure of Personal Information or restriction of processing of Personal Information or to object to such processing; the right to lodge a complaint with a supervisory authority; where the Personal Information are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling; and the appropriate safeguards relating to the transfer of your Personal Information outside the EEA.
• The right to request the correction of inaccurate Personal Information we hold about you.
• Under some circumstances, the right to request that we delete your data.
• The right to restrict processing of your Personal Information.
• The right to object to processing activities, if the processing is based on our legitimate interest.
• The right to withdraw consent for processing at any time, if the processing is based on consent.
• The right to object to processing of Personal Information for direct marketing purposes at any time.
• In some circumstances, the right to request that we transfer or port elements of your data either to you or another service provider – if the processing is based on your consent and is made by automated means.
• The right to file a complaint with your Supervisory Authority (in the EEA, as prescribed by GDPR).

You may exercise these rights to the extent these rights apply to you by contacting us via the contact information listed below. We will undertake to respond to your request within the applicable time frame prescribed by applicable law, and in any event, we will make efforts to respond within 30 days of receipt of your request. Although we will make reasonable efforts to accommodate your requests, in some circumstances we may deem your request unfounded or not eligible under applicable law. If that should happen, we expressly reserve the right to refuse your Personal Information request. Before we are able to accommodate any request, provide you with any information, or correct any inaccuracies, we may verify your identity by requesting certain information or identification.

Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

CCPA Disclosure

This section is only applicable to California residents for purposes of compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Defined terms used in this section are used as such terms are defined by and interpreted pursuant to the CCPA.

The categories of Personal Information we have collected about Consumers, for of which we have disclosed for a business purpose, in the preceding 12 months are (please refer to the table at the top of this Privacy Notice for more detail):

1. Identifiers, such as name, address and email address.
2. Personal Information, as defined in the California safeguards law, such as contact information and financial information.
3. Commercial information, such as transaction and account information.
4. Internet or network activity information, such as browsing history and interactions.

In the past 12 months we have not “sold” Personal Information relating to California residents within the meaning of the CCPA. For purposes of this Privacy Notice, “sold” means the disclosure of Personal Information for monetary or other valuable consideration.

If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:

1. The categories of Personal Information that we collected about you and the categories of sources from which we collected such Information.
2. The business or commercial purpose for collecting Personal Information about you.
3. The categories of Personal Information about you that we disclosed to third parties for a business purpose and the categories of third parties to whom we disclosed such Personal Information (if applicable).
4. The specific pieces of Personal Information we collected about you.

If you are a California resident, you may also request that we delete Personal Information that we collected from you.

The sources we have collected this Personal Information from are directly from California residents or their representatives.

Before we are able to accommodate and respond to any request, we may ask to verify your identity by providing us with certain information or identification. In some instances, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual. In other instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights, such as information relating to our employees and contractors that is used for our employment and vendor management purposes.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA. You can email privacy@senzing.com at any time.

Changes to This Privacy Notice

We reserve the right to update or change our Privacy Notice at any time and you should check this Privacy Notice periodically. Your continued use of the Website after we post any modifications to the Privacy Notice on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Notice.

If we make any material changes to this Privacy Notice, we will place a prominent notice on our website.

Contact Us

If you have any questions about this Privacy Notice, please contact us at privacy@senzing.com.