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Our approach to website privacy

We're Egress Software Technologies Limited, part of the Egress Software Technologies Group. More information about us and our group can be found at https://www.egress.com/about.

This privacy policy sets out details about the information that we collect when you use or browse www.egress.com, our partner portal at www.egress.force.com/partner, or the apps that we make available to access our services (collectively, our Sites). By using our Sites you confirm that you accept this policy. If you don’t, then please don’t use them.

This policy describes:

  • the information we collect and how we get it
  • how we use that information
  • who we may share it with and why
  • where we may transfer and process it
  • what you need to do if you provide information to us about others

If you have any questions we’d be happy to answer them, just get in touch at dpo@egress.com.

This Website Privacy Policy was last updated on 5 July 2019.

The way we talk about the information we collect through browsing our Sites

We think about the information that we collect when you browse our Sites as falling into 2 groups:

Personal contact information

Information about you that you provide to us, or that we obtain such as:

  • name, address, phone number, email address and other contact details
  • any permissions, consents or preferences that you give us
  • how you use our Sites (where you can be identified)
  • information that we obtain from third parties that may be linked to you, your employer or your organisation

Website data

(i) Usage statistics, system logs, performance and security data, feedback data and aggregated data about how our Sites are used (e.g. performance counters, access logs, metrics, associated metadata, unique identifiers for devices, technical information about the devices used, the network, operating system and browser). (ii) data identified as malicious (e.g. malware infections, cyberattacks, unsuccessful security incidents, or other threats).

Third-party data

Information that you provide about a third-party (e.g. a prospect, business contact or business with a need for a product or service that we provide or sell).

The information we collect and how we get it

We collect information about you in a number of ways. We may combine the information that we receive from these various sources as set out further below where we explain how we use this information.

From

How we obtain or receive it

Examples of the types of information

You

  • filling out forms on our website or apps
  • contacting us
  • taking part in our competitions or promotions
  • attending our webinars. We may record our webinars, and therefore your participation in them. We will also keep a record of your attendance
  • registering to use any services that we provide (including our partner portal)
  • uploading information to our partner portal
  • Personal contact information
  • Website data
  • IP address (this may not always be personal to you – e.g. where using shared networks)
  • Third-party data

Third parties

  • publicly accessible records
  • third-party data providers who we purchase information from (e.g. name, email address, telephone number, job role, employer, market sector/industry, country)
  • making use of our Sites
  • filling out forms on our Sites and providing information about you
  • contacting us and providing information about you
  • government and law enforcement agencies
  • filling out forms on websites or webforms that we host on behalf of a third-party
  • open data and public records
  • records provided by third-parties
  • information sent by or received from third-parties
  • Personal contact information
  • Website data
  • Third-party data

General use of our services

  • Accessing and using our Sites
  • Cookies
  • Personal contact information
  • IP address (this may not always be personal to you – e.g. where using shared networks)
  • Website data

IP address

  • when you visit our Sites we will record your IP address.
  • your IP address may be kept in log files or matched against public or proprietary IP address databases to provide us with information about your visit. This may identify the organisation to whom the IP address is registered (and may in some cases enable us to identify you)
  • IP address
  • Personal contact information

How we use the data that we collect

We use the personal contact information and website data in each of the following ways.

Relationship management

What we use it for

Our reasons

Our lawful basis where you’re an individual

Our lawful basis where you’re a business

Information type

Manage, track and develop our relationship with you

Processing to complete any pre-contract processes that you request.

Performance of contract, Legitimate interests

Legitimate interests

Personal contact information

To ensure that we have a productive relationship where we’re able to meet user needs and respond to them both proactively and reactively. This is core to our business and forms the cornerstone of success. If we were unable to process personal data for this purpose, our business would cease to function properly. If you participate in the Egress Partner Programme and we were unable to process this information, we would be unable to work effectively with you in pursuing the collective aims of that programme.

Legitimate interests

Legitimate interests

Personal contact information, website data

To contact you in relation to potential sales opportunities, and to understand you and your employer or organisation better through the use of data that we receive from third party providers.

Legitimate interests

Legitimate interests

Personal contact information, website data

We may use your information to create reports or profiles (both of you and the organisations or third-parties that you provide information about) for marketing and analytics purposes.

Legitimate interests

Legitimate interests

Personal contact information, website data

Delivery of services

What we use it for

Our reasons

Our lawful basis where you’re an individual

Our lawful basis where you’re a business

Information type

Ensure our Sites are functioning properly

To ensure that we can provide the access to our Sites.

Legitimate interests

Legitimate interests

Personal contact information, website data

To provide guidance on using our Sites or other support.

Legitimate interests

Legitimate interests

Personal contact information, website data

Respond to and resolve complaints, queries and requests

To respond to your queries, complaints and to ensure that you’re able to use our Sites appropriately. This may involve the recording of calls that you make to our support desks or sales teams for training and monitoring purposes. We use a ‘follow-the-sun’ support structure which means that calls may be recorded outside the country you’re located in depending on the time of your call and the support staff responding.

Legitimate interests

Legitimate interests

Personal contact information, website data, Third party data

Alert you to issues or updates to our partner portal

To ensure that you’re presented with relevant information if we change aspects of our partner portal and decide to alert users to those changes.

Not applicable

Legitimate interests

Personal contact information, website data

Service information by electronic means

If you use our partner portal we may send, or otherwise display, to you information about the portal (e.g. how you use it, how you could do so more efficiently, faults, issues, updates or notices of times when it won’t be available).

Not applicable

Legitimate interests

Personal contact information, website data

Delivering on contractual obligations and exercising rights

What we use it for

Our reasons

Our lawful basis where you’re an individual

Our lawful basis where you’re a business

Information type

Make and manage payments made by, or due to, you, your employer or your organisation

Processing to achieve this purpose may take place both pre and post contract agreement (e.g. initial subscription payment and renewals).

Performance of contract, Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data

Meet and perform our audit obligations

We recognise that processing may be required in order for our own compliance purposes (e.g. to ensure that our financial processes are accurate and working properly).

Legitimate interests, Legal obligation

Legitimate interests, Legal obligation

Personal contact information, website data, Third-party data

Recover money owed to us or other companies in our group

To ensure that payments are both made and timely

Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data

Exercising our rights

We may need to process certain information (including personal data) in order to exercise or enforce our rights under our agreement with you (including this and any other relevant policies).

Legitimate interests, Legal obligation

Legitimate interests, Legal obligation

Personal contact information, website data, Third-party data

Progressing opportunities provided by you through our Partner Portal

If you use our partner portal, once you’ve provided Third-party data through it to us, we’ll use it to progress the opportunity (if any) including to qualify the Third-party data as a lead and, where possible, close it out to a sale. Third-party data is held by us as an independent controller, not a joint controller with you.

Not applicable

Legitimate interests

Personal contact information, website data, Third-party data

Legal and regulatory risk management

What we use it for

Our reasons

Our lawful basis where you’re an individual

Our lawful basis where you’re a business

Information type

Detect and prevent crime

To ensure that we and our group can both detect and report criminal activity

Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data

Manage risk for us, our group and users

To ensure that we and our group can manage legal and regulatory risk and do so in the most appropriate and compliant manner

Legitimate interests, Legal obligation

Legitimate interests, Legal obligation

Personal contact information, website data, Third-party data

Obey our or our group’s legal obligations

To ensure that we and our group can manage legal and regulatory risk and requests in the most appropriate and compliant manner. This may include adapting the way we and our group operates or engages to meet new or future obligations

Legitimate interests, Legal obligation

Legitimate interests, Legal obligation

Personal contact information, website data, Third-party data

Keep our records accurate and up-to-date

Processing to ensure we meet our obligations in respect of data accuracy (this may include acting in response to your notifications)

Legitimate interests, Legal obligation

Legitimate interests, Legal obligation

Personal contact information, website data, Third-party data

Run our and our group’s businesses in an efficient and proper way

We use shared systems, activities, suppliers and sub-processors in order to help manage legal and regulatory risk within our group, and to operate in a way that ensures quality, consistency and security of service delivery

Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data

Innovation and system development

What we use it for

Our reasons

Our lawful basis where you’re an individual

Our lawful basis where you’re a business

Information type

Develop new systems, features, functionality and ways to meet user needs

We have a legitimate interest to understand how our Sites are used, and to look at areas where user needs could be met either as new functionality, or in improved ways

Legitimate interests

Legitimate interests

Personal contact information, website data

Study how users are using our Sites

We have a legitimate interest to understand how our Sites are used, and how users benefit from the services that we provide to them

Legitimate interests

Legitimate interests

Personal contact information, website data

Test new products and services

We have a legitimate interest in ensuring that prior to being launched, functionality operates in a secure and efficient manner

Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data

Show you the right Sites

To ensure that you enter into any contractual relationship with the right company in our group. This also enables us to present content relevant to that jurisdiction where appropriate

Legitimate interests

Legitimate interests

Personal contact information, website data, IP address, Third-party data

To create anonymous reports and statistics

We have a legitimate interest in understanding market risks, trends and activities and, where relevant, utilising the anonymous insights that we can gain from our Sites in the provision of both internal and publicly available reports, blogs and other communications.

Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data

Marketing and promotion

What we use it for

Our reasons

Our lawful basis where you’re an individual

Our lawful basis where you’re a business

Information type

To develop and carry out marketing activities

We have a legitimate interest to conduct marketing, promotional and other advertising activities in order to grow our brand, and the awareness of our products and services. We may use information that we source from third-party data providers to contact you where this is permitted by law. We may also use information we collect about the domain of your email address (e.g. about your employer or organisation, it’s sector/industry) or that we can relate back to you (e.g. through cookies) about the products you’re interested in to tailor our communications and make them more relevant to you.

When you download a whitepaper through our website, the information you provide may be initially stored in the US or Singapore before being transferred to us if those countries are closer to you than the EEA or UK.

Legitimate interests, Consent

Legitimate interests

Personal contact information, website data

To enable your participation in competitions and promotions

Where you’ve elected to take part, we will process your information in order to enable you to participate.

Consent

N/A

Personal contact information, website data

We may use information that we hold about you (or if you’re a business, your users) to send information about our and our group companies’ products and services. This may be by email or other electronic means available to us in the future. We may use other information available to us in order to tailor our communications. If you’re an individual in most circumstances we’ll only do this if we have your consent but there may be some situations where we have a legitimate interest in doing so (e.g. where you complete a purchase through our online ecommerce platform).

If you’ve given your consent, you can withdraw this at any time, or if we’re reliant on our Legitimate interests for sending you marketing you can object. In either case, just let us know using the details at www.egress.com/legal/your-rights.

If you provide us with information about others

If you or your business provide information to us about another person or business (such as Third-party data) you must make sure you have the right and permission to do so (e.g. by providing appropriate data collection notices to individuals who are the subject of Third-party data). We’re reliant on this in order to receive and process the information you provide. By providing it, you confirm that you do.

Ownership of Third-party data: Once you’ve uploaded Third-party data to our partner portal, we hold that information (including any personal data within it) as a controller. You may yourself be an independent controller, not a joint controller, of some or all of that Third-party data. We are therefore free to use Third-party data for our own purposes and to determine when, how and where it is processed (subject to compliance with relevant data protection laws).

Who we may share your information with, and sending information outside the country you’re located in

Details of the subcontractors used in the provision of our Sites, marketing activity, prospect and customer relationship management, and in the delivery of our services can be found through the subcontractor page available at www.egress.com/subcontractors. We share your information with these third-parties to help with our business activities and delivery of our services. They are only authorised to use your personal information as necessary to provide the services to us that we request from them and must abide by data privacy and security obligations set out in applicable law.

Where any transfer outside of the country or region that you’re located in (e.g. the European Economic Area (EEA), the United States or the UK) occurs, we’ll ensure that any such transfer or processing is subject to appropriate legal and technical safeguards with our subcontractors in line with local law requirements.

Provision of Partner Portal: We use Salesforce, Inc. to provide both our Portal and the CRM system that information provided through it is stored on. Details about Salesforce’s approach to privacy can be found at https://www.salesforce.com/uk/company/privacy/.

Transfer of rights: We reserve the right to transfer our obligations, rights and permissions in personal contact information and website data to any organisation to which we may transfer our business or assets (including if we, or a relevant part of us or our assets, are proposed to be purchased or acquired by a third party).

Selling your information: We will not, and do not, sell your information for valuable consideration (as defined in the California Consumer Privacy Act). Your information may be shared with third parties as set out above for our business purposes.

Applicable law: We reserve the right to disclose personal contact information and website data in order to comply with national, EU or Member State law to which we’re subject, including to meet national security and law enforcement requirements. You can find out more on our approach here.

What we need you to do

We need to make sure that the information that we hold about you is accurate, up-to-date and still relevant. As a result, we need you to tell us promptly if there are any changes to the information that you provide by letting us know at DPO@egress.com.

How long we'll keep your information for

We’ll keep information in accordance with our data retention policies available at www.egress.com/legal, including to maintain records required for legal or regulatory reasons, to show that we complied with our contractual obligations, to respond to any complaints or queries, and for research and statistical purposes.

Your rights as an individual

As an individual user of our Sites, you may have certain rights by law in respect of the personal data that we hold about you. These rights may not always apply as your location and the basis on which we’re processing your personal data may affect their availability. You can find out more information about them and our Data Protection Officer at www.egress.com/legal/your-rights.

If you no longer wish to receive direct marketing emails from us, you may opt out of receiving these emails by clicking on the Unsubscribe link at the bottom of any marketing email you receive. We are looking to introduce tools to help you manage your marketing preferences with us (e.g. if you’d still like to receive information, but only on certain topics). Once this is available, you’ll find links to it at the bottom of emails as well.

If you ever have a complaint relating to the delivery of our services, or our processing of your personal information, you can find details on how to raise this in our Complaints Policy at www.egress.com/legal.

Privacy Shield

We participate in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and have self-certified to the U.S. Department of Commerce our adherence to the Privacy Shield Principles for all personal information received from countries in the European Economic Area, Switzerland, and the United Kingdom in reliance on the Privacy Shield. To learn more about Privacy Shield, visit the Privacy Shield website at www.privacyshield.gov/list.

Under Privacy Shield, we are responsible for the processing of personal information we receive and subsequently transfer to a third party acting for or on our behalf. We are liable for ensuring that the third parties we engage support our Privacy Shield commitments. The U.S. Federal Trade Commission has regulatory enforcement authority over our processing of personal information received or transferred pursuant to Privacy Shield. We commit to cooperate and comply with the advice of the regulatory authorities to whom you may raise a concern about our processing of personal information about you pursuant to Privacy Shield, including to the panel established by the EU authorities and the Swiss FDPIC. This is provided at no cost to you.

If you don’t feel that we’ve resolved your complaint or concern satisfactorily you can contact our U.S. based third-party dispute provider (free or charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Cookies

To find out more about cookies and how we use them, see www.egress.com/cookies. If you live in California, we need to let you know that some web browsers may transmit “do-not-track” signals to the websites and online services you communicate with. Whilst there is no industry standard that governs what, if anything, we should do if we receive such a signal, our website will not set cookies if you have your browser set to ‘Do not track’

Changes to this policy

We can change this policy from time to time. You should check the website periodically to make sure that you have read our most recent policy. When we do make changes, we’ll change the date at the top of this document.

About us and applicable law

We’re the Egress Software Technologies Group. You can find out more details about us at www.egress.com/about and you can contact us at info@egress.com. When contacting us we strongly recommend you don’t email us confidential or personal information. If you do, it’s at your own risk although the terms of this policy will apply to our use of that information.

Where you're resident

Who we are

Governing law

Courts with exclusive jurisdiction

Special terms

North America

Egress Software Technologies, Inc.

A Massachusetts corporation.

Office: Suite 2, Level 3, 268 Summer Street, Boston, MA 02110, United States

State of Delaware (without regard to its conflict of law principles).

State or federal courts in and for Boston, Massachusetts

Where applicable, each of us hereby waives its respective rights to a jury trial of any claim or cause of action relating to or arising out of this policy. This waiver is intended to encompass all disputes that may be filed in any court and that relate to the subject matter of this policy (including contract, tort, breach of duty and all other common law and statutory claims).

Rest of the World

Egress Software Technologies Limited.

Registered in England and Wales (number 06393598).

Registered office: 12th Floor, The White Collar Factory, 1 Old Street Yard, London, EC1Y 8AF, United Kingdom.

VAT number: 921 4606 46.

England and Wales (except if you're a consumer resident of Northern Ireland or Scotland when you may bring proceedings there)

Courts of England and Wales (except if you're a consumer resident of Northern Ireland or Scotland and have brought proceedings there when the Northern Irish or Scottish Courts will have jurisdiction).

N/A

Our Sites are provided by Egress Software Technologies Limited, registered in England and Wales (number 06393598) for and on behalf of itself and the other members of the Egress Software Technologies Group.

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