THIRD PARTY PRIVACY NOTICE – EU DATA SUBJECTS
This privacy notice is provided in accordance with the General Data Protection Regulation (“GDPR”) and any EU national laws implementing or supplementing the same (the “Data Privacy Laws”). Its provisions are only applicable to those persons who are EU data subjects, i.e., those persons currently present in the EU or European Economic Area (EEA) or who provided their personal data while present in the EU or EEA.
IGI and its subcontractors (collectively, the “Firm”, “we”, “us”, “our”) are committed to complying with the applicable data privacy and security requirements in the countries in which they operate. The Firm complies with internationally recognized standards of privacy protection, and with various privacy laws globally including, but not limited to, the GDPR.
To the extent that the Firm is deemed to be a data controller under Data Privacy Laws, this notice fulfils our obligation to provide certain information to third parties whose personal data we process in this capacity as required by Article 14 of the GDPR.
Who is Collecting Data?
Data will be collected by the Firm.
Data We Collect
The Firm collects the following categories of personal data through our website:
Contact data: Through our “Contact” form, we may collect information about data subjects such as name and contact details (email, phone number, etc.) in order to communicate and facilitate the provision of our services with our clients or potential clients.
Website visitor information:
When you visit our website, we use Google Analytics. Google Analytics is Google’s free web analytics tool that helps us to understand how our visitors engage with our websites. Google Analytics collects information anonymously and it reports website trends without identifying individual visitors. Analytics uses its own set of Cookies to track visitor interactions. These Cookies are used to store information, such as what time the current visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page. Google Analytics customers can view a variety of reports about how visitors interact with their website so they can improve their website and how people find it. A different set of cookies is used for each website, and visitors are not tracked across multiple sites. Analytics customers are obliged to notify users of their use of analytics software. To disable this type of Cookie, some browsers will indicate when a Cookie is being sent and allow you to decline Cookies on a case-by-case basis. In addition to declining Cookies, you can also install the Google Analytics Opt-out Add-on in your browser, which prevents Google Analytics from collecting information about your website visits. You can opt out by clicking here.
Processing of Personal Data
We collect personal data to offer and administer our services.
The data you provide to us will be processed in accordance with the purposes specified in this notice, namely:
- To provide the products or perform the services requested by clients and individuals pursuant to a letter of engagement, statement of work, or similar (where the processing is necessary for our legitimate business interests in conducting and managing our business).
- To provide the products or perform the services requested by clients and individuals using our website (where the processing is necessary for our legitimate business interests in conducting and managing our business).
- For complying with obligations provided by laws, current regulations and European legislation (e.g. tax regulations) (where processing is based on a legal obligation).
- For legitimate business purposes to advise you through e-mail, phone call, or post, in the framework of our ordinary commercial relationship, about other products or services similar to the products or services we have provided to you and that we think will be of interest to you (where the processing is necessary for our legitimate business interests).
- For marketing purposes. For example, we may use your information to further discuss your interest in the services and to send you information regarding the Firm and its group companies such as information about promotions, events, products or services. You can withdraw your consent or opt out of receiving our marketing communications at any time. If you are not located in the EU, you may opt-out of receiving marketing communications and updates at any time. You can manage your receipt of marketing and non-transactional communications by clicking on the «unsubscribe» link located on the bottom of the Firm’s marketing emails. Additionally, you may send a request to firstname.lastname@example.org.
- For improving the Firm’s communications with you. Emails sent to you by the Firm may include standard tracking, including open and click activities. The Firm may collect information about your activity as you interact with our email messages and related content.
- For operating and improving the Firm’s website and your customer experience. For example, we may collect and analyze data on your use of our website and process it for the purpose of improving our online experience.
- For security purposes. For example, we may use your data to protect the Firm and its third parties against security breaches and to prevent fraud and violation of the Firm’s applicable agreements (where the processing is necessary for our legitimate business interests).
Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You have the right to object to this processing if you wish.
How Data is Processed
Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and in compliance with current regulations. We permit only authorized Firm employees and third-party providers to have access to your information. Such employees and third-party providers are appropriately designated and trained to process data only according to the instructions we provide them.
Storage of Personal Data
The Firm will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with state, local, federal regulations, or country specific regulations and requirements and for the period comprising the statute of limitations for any potential contractual litigation.
Disclosure/Sharing of Personal Data
We only share your personal data with your consent or in accordance with this notice. We will not otherwise share, sell or distribute any of the information you provide to us except as described in this notice.
We share personal data among Firm-controlled affiliates and subsidiaries who act for the Firm for the purposes set out in this notice.
The Firm may share your information with external third parties, such as vendors, consultants, legal advisors, auditors and other service providers who are performing, advising or assisting with certain services on behalf of the Firm. Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable contract, and not for any other purpose. The Firm requires these third parties to undertake security measures consistent with the protections specified in this notice.
The Firm may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
If the Firm’s business enters into a joint venture with or is merged with another business entity, your information may be disclosed to our new business partners.
Cross – Border Transfers of Personal Data
Personal information may be transferred, accessed and stored globally as necessary for the uses stated above in accordance with this notice, and in compliance with local law and regulations.
Data concerning EU data subjects may be transferred to or processed in locations outside of the EU only where one of the following safeguards is in effect:
- Transfers to certain countries which the EU Commission has determined ensure an adequate level of protection (including via participation in the EU-U.S. Privacy Shield)
- Transfers pursuant to standard contractual clauses or contract terms ensuring adequate data protection
You have the following rights concerning your data processed by The Firm:
Access: You have the right to access personal information that The Firm holds about you.
Rectification: You have the right to ask us to rectify information The Firm holds about you if it is inaccurate or not complete.
Erasure: You can request that The Firm erase your personal data. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.
Restrict Processing: You have the right to ask The Firm to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.
Object to processing: Where processing is based on legitimate interests, you have the right to object to The Firm processing your data. The Firm will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.
Portability: Where processing is based on consent or performance of a contract, you have the right to data portability. The Firm must allow you to obtain and reuse your personal data for your own purposes in a safe and secure way without this effecting the usability of your data. This right only applies to personal data that you have provided to The Firm as the Data Controller.
Please contact email@example.com to request access, rectification, or erasure, or to restrict processing, to object to processing, to request data portability.
Automated Decision Making
Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.
The Firm does not make automated decisions using personal data. If automated decisions are to be made, affected persons will be given an opportunity to express their views on the automated decision in question and object to it.
Providing Information to the Firm
If you choose not to provide certain personal information, it may be an impediment to the exchange of information necessary for the execution of the contract or provision of services, and we may not be able to provide you with some services and you may not be able to participate in some of the activities on our website(s).
Third Party Websites or Other Services
We are not responsible for the privacy practices of any non-Firm operated websites, mobile apps or other digital services, including those that may be linked through the Firm’s websites or services, and we encourage you to review the privacy policies or notices published thereon.
Please contact us at the Firm with questions, concerns, or complaints: firstname.lastname@example.org.