The European Union General Data Protection Regulation 2016/679 (“GDPR”) imposes requirements regarding the collection, use, and disclosure of personal information in relation to our commercial activities, as does private-sector privacy legislation in their local jurisdictions, provinces and territories.
THIS EU POLICY APPLIES TO ALL PERSONAL INFORMATION ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH A SITE OR OTHERWISE).
Personal Information. Under European privacy laws (and in this EU Policy), personal information is generally any information about an identifiable individual. It may include your name, age, mailing address, residential phone number, or e-mail address, personal history (including financial and credit information, donations, personal health information, billing history, personal family and relationship matters, and penal or criminal information), personal information related to corporate involvements, work experience (past and present), discipline, income and benefits, medical records, tax records, and security clearances. The term does not include your name, business title, business address, or business telephone number in your capacity as an employee of an organization or enterprise.
Collection of Personal Information. When you visit our website, use our services, or otherwise interact with CeloNova, we will collect the kind of standard, non-sensitive information you would expect a business to business data processor to request. For example, we may ask for your:
- Your name
- Your job title
- Your job role
- Your email address and contact number
- Your postal address
- The name of the organisation you work for
- And we will collect and store data on the transactions and you make with us
We collect such information in order to provide services and products to our business clients. We often collect personal information from you or from third parties and as a Data Processor or agent on behalf of a Data Controller or third-party, where we have received the requisite consent to do so or as otherwise permitted by law. Third parties include, as examples, organizations to whom we provide services or products, and organizations that perform outsourcing and other services for us.
Where we are the Data Controller with regard to that data we will inform you how you can exercise your rights as a data subject, including the right to object to the processing of your personal data.
How We Use Personal Information. As a general matter, we collect your personal information primarily to provide services to our business to business customers, for administrative or management requirements, and to enhance our relationship with customers. We will only process personal data for specific purposes or for any other purposes specifically permitted by the applicable data protection legislation.
CeloNova does not sell, rent or lease its customer lists to third parties.
CeloNova will disclose your personal information, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on CeloNova or the site; (b) protect and defend the rights or property of CeloNova; and, (c) act under exigent circumstances to protect the personal safety of users of CeloNova, or the public.
We may share your personal information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of CeloNova’s business or assets to such business entity (including due to a sale in connection with a bankruptcy). We will require any such purchaser, assignee or other successor business entity to honor the terms of this privacy statement.
We rely on the following legal grounds to process your personal information, namely:
- Performance of a contract – We may need to collect and use your personal information to enter into a contract or to perform a contract that you or your company has with us.
- Consent – Where required by applicable laws, we will rely on your consent for collecting your personal information.
- Legitimate interests – We may use your personal information for our legitimate interests to improve our products and services. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use technical information to improve our products and use personal information for our marketing purposes.
Obtaining Consent. Except when otherwise permitted by law, we obtain the requisite consent prior to collecting and, in any case, prior to using or disclosing your personal information for any purpose. You may provide your consent to us orally, in writing, by electronic communication, or any other means reasonably capable of conveying your consent. We will obtain your express consent if we collect, use or disclose sensitive information as Data Controller. Your consent may also be intrinsic to the circumstances such as in the case where you have already provided personal information to us and you maintain your relationship with us or where you provide our representatives with your phone number so that we can contact you. Except when otherwise permitted by law, we will only use the information for the purpose for which it was given. From time to time, we may collect, utilize, or disclose your personal information based on your consent or as otherwise permitted by law.
When your consent is required, you can withdraw consent at any time (unless withdrawing the consent would frustrate the performance of legal obligations) upon providing to us a 30-day notice. However, the withdrawal of your consent may adversely affect our ability to provide services to you and to maintain our relationship.
Opt-Out. If you no longer wish to receive marketing communications from us, you can let us know by sending an email to firstname.lastname@example.org.
Your Choices And Access To Your Personal Information. Subject to the exceptions provided by the applicable law, we will make available to you any specific personal information about you that we have collected, utilized or disclosed, upon your written request. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes and using an alternative format, if required. GDPR allows data subjects the rights of access, rectification, erasure, restriction, objection or portability in line with the type of services being provided and the right to lodge a complaint to your Supervisory Authority.
You may send your data subject request to exercise any of the above stated rights, by completing the request form and e-mail it to email@example.com. Please be as specific as possible in your request so that we can meet the applicable time lines.
Response Times. We will make every reasonable effort to respond to each of your written requests not later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate individual EU or EEA country privacy commission with respect to this time limit.
Costs. We expect to provide access without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction, or transmission of personal information. We will notify you, following your request for transcription, reproduction, or transmission, of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.
Identifying You In Connection With Requests. We may require that you provide to us sufficient information to identify yourself before we provide information about the existence, use, or disclosure of your personal information in our possession. Any such information shall be used only for this purpose.
Accuracy. We will use reasonable efforts to ensure that your personal information is kept as accurate, complete, and up-to-date as possible. We will not routinely update your personal information, unless such a process is necessary. In order to help us maintain and ensure that your personal information is accurate and up to date, you must inform us, without delay, of any change in the information you provided to us.
You can at any time, challenge the accuracy or completeness of the personal information we have about you, subject to the exceptions provided by applicable law. If you successfully demonstrate that the personal information we have on you is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended information to third parties to whom we have communicated your personal information.
Limitations. We only collect the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by applicable law. We do not use or disclose your personal information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law. We do not, as a condition of providing services to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond that reasonably required for such purposes, or to comply with our obligations under applicable law.
Retention Of Personal Information. We may keep a record of your personal information, including correspondence or comments. We will utilize, disclose, or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal information. When personal information is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal compliance and data retention policies.
Third Parties. We remain responsible for all personal information communicated to third parties for processing. As such, we ensure that third parties that are engaged to provide products or services on our behalf and are provided with personal information are required to observe the intent of this EU Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclosure the personal information for any purpose other than the purpose for which the personal information was communicated.
Safeguards. We use security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances, and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption.
Dirk Pauwels, CeloNova’s EU Privacy Officer
8023 Vantage Dr. Suite 1400
San Antonio, TX 78230-4726
CELONOVA COOKIES POLICY
Our Site may use first and third-party cookies for technical, analytical and advertising purposes. “First party cookies” refer to cookies that are set by our Site, and we are the only ones with access to this information. On the other hand, “third party cookies” or requests allow other third parties to have access to the information collected. Not all cookies are necessary to navigate this Site. Cookies used for analytical and advertising purposes, such as site analytics and advertising cookies (non-essential cookies) are not necessary to navigate our Site. You have the choice not to accept or delete them anytime, and carry on browsing normally.
What are cookies and why do we use them?
Cookies are files that are downloaded on your computer or mobile device when you visit certain websites. Cookies allow a website, for instance, to identify a user session, recall your preferences (e.g. language), or gather information about your browsing habits. We use essential cookies for our legitimate interest in facilitating your access to and use of the Site, and we ask your consent for using advertising and analytics cookies (non-essential cookies) so we can measure how you interact with the Site content. However, you can withdraw your consent at any time.
We may send a cookie which may be stored by your browser on your computer’s hard drive. We use this information for the following purposes:
- Assisting you in navigation on the Site
- Improve the functionality of the Site
- Store login details for our secure Site(s)
- System administration
- Reporting information for research purposes
- Assisting with our promotional and marketing efforts.
We also may use “clear gif” pixels in HTML-based emails sent to our users to track which emails are opened by recipients. We may use the information we obtain from the cookie in the administration of this Site, to improve the Site’s usability and for marketing purposes. We may also use that information to recognize your computer or mobile device when you visit our Site, and to personalize our Site for you.
Cookies and information captured through this Site are; stored for a certain retention period; however you can eliminate these cookies any time before the cookie expiration date.
How to Restrict Cookies
You can adjust the settings in your browser in order to restrict or block cookies that are set by the services or information you access on our Site (or any other website on the Internet). Your browser may include information on how to adjust your settings. Alternatively, you may visit www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers. This site also explains how to delete cookies from your computer.
You can control and delete these cookies through your browser settings through the following links:
- Google Chrome
- Mozilla Firefox
- Microsoft Internet Explorer
- Safari for iOS (iPhone and iPad)
- Chrome for Android
- Windows Phone
Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.
Please be aware that restricting cookies may impact the functionality of the Site. Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools”,” “Internet Options”,” “Privacy”,” and selecting “Block all cookies”). This will, however, have a negative impact upon the usability of many websites, including this Site.