Last Updated: June 2018
- When you make use of our website, https://www.controlup.com/ (“ Website ”);
- When you attend a marketing event and provide Personal Data; and
Table of contents:
- What Information we Collect, Why we Collect it, and How it is Used;
- How we Protect and Store your Personal Data;
- How we share your Personal Data
- Additional Information Regarding Transfers of Personal Data
- Your Rights
- Use by Children
- How to Contact Us
- Links to and Interaction with Third Party Products
- California Privacy Rights
- Our California Do Not Track Notice
- Deletion of Content from California Residents
|Use Case||Data We Collect||Why is the Data Collected and for What Purposes?||Legal basis||Third Parties with Whom we Share your Data||Period of Storage||Consequences of not Providing the Data|
|When you make use of our Website||Cookies||When you use our Website, we will collect and receive information collected from cookies implemented by third parties, in order to improve our Website and target you relevant with marketing campaigns on social media or by email.
||3 rd party cookies are stored by default for 180 days unless deleted by the user||We will not be able to improve our Website or provide you with content and offers which may be of interest to you.|
|First name, last name, email address, company name (optional), country, phone number and the content of your request or inquiry.||When you commence direct communications with us by sending us a request or inquiry via the Website (filling a web form), we collect this to respond to your request||Necessary in order to take steps at your request prior to entering into a contract
Legitimate interest –Necessary to respond to your request inquiry
||For as long as it is reasonably necessary for us to adequately respond to your request but no longer than 24 months after the last communication by the user.||We will not be able to respond to you request or inquiry.
You would not be able to download gated content assets and free utilities software pursuant to your request.
|Name, email address||When you commence direct communications with us via the chat on our Website, we collect this to respond to your request||Necessary in order to take steps at your request prior to entering into a contract
Legitimate interest – take steps to respond to you inquiry.
||For as long as is reasonably necessary for us to adequately respond to your request but no longer than 24 months after the last communication by the user.||We will not be able to respond to you request or inquiry and provide you support|
|Name, email, you preferred job and your resume which you upload to the Website||When you submit your resume for one of the positions offered on our Website.||Necessary in order to take steps at your request prior to entering into a contract
Legitimate interest – get in touch with you with and assess whether you fit the job description.
|G-drive||2 years||We will not be able to assess whether you fit the job description or contact you in connection with you application.|
|When you attend a marketing event and provide Personal Data;||First name, last name, email, telephone number||When you provide us with Personal Information when attending, or registering to attend a trade show, conference or webinar||Consent||
||No longer than 24 months after the last communication by the user.||We will not be able to get in touch with you.|
2.2 Retention of your Personal Data . In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
In addition to the recipients described in Section 1, we may share your information as follows:
- To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order
- .If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets.
- Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
We ensure transfers within the ControlUp group will be covered by an agreement entered into by members of the ControlUp group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to;
Where we transfer your Personal Data outside of ControlUp group, for example to third parties who help provide our products and services, we will obtain commitments from them to protect your Personal Data. Some of these assurances are well-recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States; or
Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed;
The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR:
- You have a right to access information held about you. Your right of access is normally be exercised free of charge, however, we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
- You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading.
- You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
- The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
- The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
- You have the right to object to profiling;
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
- The right to withdraw your consent. Please note that t there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
- You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
You can exercise your rights by contacting us at [ email@example.com ]. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested for you. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive.
In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
We do not offer our products or services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without the involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at firstname.lastname@example.org .
- CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com . Please note that we are only required to respond to one request per customer each year.
We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses the Website.
If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Data you have publicly posted. If you wish to remove such content or Personal Data and you specify which content or Personal Data you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Data you have posted and that there may be circumstances in which the law does not require us to enable removal of content.