- What Personal Information We Collect and How We Collect It. We do not currently require you to provide Personal Information in order to have access to general information available on the Site. But, we do receive and/or collect Personal Information from you in the following ways:
- Account and Online Registration. In order to use certain services that we offer via the Site, you may be required to create an account (“Account”) or submit an online registration form (such as when signing up to receive a beta version of the SeaLights software or to receive our newsletter). If you create an Account or submit an online registration form, you will be required to provide us with certain information, such as your name, email address and/or mobile phone number, as well as a password, that you will use for your Account, if applicable. You may also choose to provide additional Personal Information as part of the Account or other registration process, such as your age and gender. We may send you a text message to your mobile phone or an email to the email address you submit to confirm your registration. If you choose not to create an Account or submit an online registration form, you may not be able to access or use certain features of the Site.
- Third Party Accounts. You may choose to create an Account by clicking on a ‘connect’ or ‘sign-in’ button that we may display on the Site for a designated third party website or service (each a “Third Party Account“), such as Facebook or Doing so will enable you to link your Account and your Third Party Account. If you choose this option, then you will be required to approve the connection as well as the types of information (which may include Personal Information) that we will obtain from your Third Party Account and the types of activities that we may perform in connection with your Third Party Account. Please note that in order to use this option, you will need to have, and may need to be signed-in to, an existing Third Party Account.
- ‘Contact Us’ Information. If you send us a “Contact Us” request, whether by submitting an online form that we make available or by sending an email to an email address that we display, you may be required to provide us with certain information such as your name and email address and other information in connection with your background if you are interested in applying for a position with SeaLights.
- Share with Friends Service. The Site may enable you to invite your friends to use our Site by sending them an invitation email or message. You may do so by: (i) using the Site to send or post an invitation message via your Third Party Account; and/or (ii) using the Site to send an invitation email to your friend’s external email address (for example, a gmail address). If you send or post an invitation message we may collect Personal Information about the recipient such as their email address or their party website account user name and ID.
- Profile. Some parts of the Site may enable you to build a public profile in connection with your Account (“Public Profile”). Your Public Profile will include your name and possibly other information that you choose to include in your Public Profile, such as your gender and a profile picture.
- Log Files. We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.
- Cookies and Other Tracking Technologies. Our Site may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Site and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
- Publicly Available Information. Your Public Profile and any content that you post on or via the Site (“User Submissions”) may be publicly available to other Site users, and may also be accessed and used by people off the Site. The notices and tools that we provide on the Site are intended to inform you which information will be made publicly available. If you publish your contact information in any User Submissions or as part of your Public Profile, you may receive unsolicited messages from other users of the Site or the public. We, therefore, encourage you only to post information that you are sure you want to be accessible to anyone.
- The Way We Use Personal Information. If you submit or we collect Personal Information through the Site, then we may use such Personal Information in the following ways, via any applicable communication channel, including email, SMS, etc.:
- We will use your Personal Information to provide and improve our Site, to send you marketing/advertisement communications that we believe may be of interest to you, to contact you in connection with the Site and certain programs or offerings that you may have registered for, and to identify and authenticate your access to the parts of the Site that you are authorized to access.
- We may use your designated email address to: (i) send you updates or news regarding the Site and our products; and/or (ii) respond to a “Contact Us” or administrative request (for example, to change your password).
- If you choose to send your friend an invitation email or message we will use the contact information that you provide, or make available, to automatically send your friend an invitation email or message. Your name and email address may be included in the invitation email or message.
- We may disclose your Personal Information or any information you submitted via the Site if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of SeaLights, our users, yourself or the public.
- Use of Anonymous Information. We may use Anonymous Information (as defined below) or disclose it to third party service providers in order to improve our Site and enhance your experience with the Site. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our Site.
- Opting Out. You may choose not to receive future promotional, advertising, or other Site-related emails from us by selecting an unsubscribe link at the bottom of each email that we send. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate your use of the Site.
- At all times, you may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory Personal Information, you may still visit parts of the Site, but you may be unable to access certain options, programs, offers, and services that involve our interaction with you.
- Access/Accuracy. To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may submit an access request by sending an email to email@example.com. Your email should include adequate details of your request.
- Children’s Privacy. The Site is not structured to attract children under the age of 13 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 13 years. If we learn that we have collected Personal Information from a child under 13 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at firstname.lastname@example.org.
- The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use reasonable acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Service, you can contact us at email@example.com.
- Merger, Sale or Bankruptcy. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events.
- 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 Information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org. Please note that we are only required to respond to one request per customer each year.
- Our California Do Not Track Notice. 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 web sites 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 web sites when a consumer uses the Site.
- Deletion of Content from California Residents. 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 Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information 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 Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
Thanks for using SeaLights Quality Intelligence Platform! We’re constantly striving to provide the best customer experience. This is part of our ongoing commitment to be transparent about how we use your data and keep it safe. This update provides an overview of how SeaLights is working towards the full implementation of General Data Protection Regulation (GDPR) -required technical and organizational measures to best support its customers in protecting personal data and exercise their rights. We have included changes to address the new standards introduced by the European data protection law and the update will be effective starting May 25, 2018.
Here’s the highlight of what we’re up to:
- We’re preparing for the EU’s General Data Protection Regulation (GDPR). This means new requirements as to how we process EU personal data. We embrace these changes, and our policy updates are intended to reflect the transparency this law requires.
- SeaLights takes data protection, data security, and regulatory compliance very seriously. We are already SOC 2-compliant, and we currently rely on Amazon’s GDPR-compliant infrastructure through the hosting services we provide through Amazon Web Services (AWS).
- The data subject is the sole owner of any personal data that is stored with SeaLights through our cloud-based services. Sealights acts as a processor of this data. You can utilize the capabilities built into the Sealights business offering to meet your own GDPR obligations related to the rights of data subjects, such as deletion and rectification of data, data access and transfer, and data subjects’ objection to the automated processing of personal data.
- SeaLights’ services do not support a download of copies of data subjects’ data, without requiring assistance from us or our partners. We are committed to delivering data portability to the customer upon demand, in a reasonable amount of time.
- When SeaLights envisions a new product or service, privacy and data protection are considered at each phase of development. This is part of our approach to GDPR-based privacy by design and by default, which describes not only how we build products, but also how we operate our services and structure our internal governance practices.
- When a customer terminates its agreement to SeaLights’ services, we retain any personal data in a limited and restricted manner (as our customer contracts detail) to extract its data. Thereafter, all data is deleted.
- SeaLghts applies processes and methods to protect and monitor all personal data maintained by us. We understand that the security risks and challenges are evolving, therefore we will constantly monitor emerging security risk and re-assess our organizational preparedness.
Any questions, request or comments, send us a message at email@example.com.
We hope you’ll find these updates improve your customer experience and reinforce our commitment to your data privacy and security.
Thank you for being SeaLights Customer.
- When you exchange business cards or emails with us;
- When you write an email to our employees;
- When you talk with our employees;
- When you attend a marketing event, webinar or trade show and provide us with Personal Data;
- When we acquire your Personal Data from third-party sources (such as lead-generation companies); and
- When you register a webinar with third-party sources, SeaLights has the rights to provide them with your details.
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
- WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
|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|
|Personal data such as:
|To offer you potential deals and send you marketing and commercial communications.
Respond to your requests and/or questions.
necessary for the purpose of our legitimate interest to market, promote and demonstrate our services, that you may seek or we think might be of interest to you/your company.
|CRM platforms (such as Salesforce, SalesLoft)
Hosting Services (Such as AWS)
- HOW WE PROTECT AND STORE YOUR INFORMATION
- 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.
- HOW WE SHARE YOUR PERSONAL INFORMATION
In addition to the recipients described in Section 1, we may share your Personal Data 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 Personal Data to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
- ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION
- Where we transfer your Personal Data outside of SeaLights, for example to third parties mention in Section 1 above, we will obtain contractual 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. We bring to your attention that Israel is a country declared as offering adequate level of data protection (see here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en)
- Where we receive requests for Personal Data from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
- Where you have provided your consent to us using the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
- YOUR RIGHTS
- Among others, the following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR:
- You have the right to request that we amend any Personal Data we hold that it is inaccurate.
- 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.
- 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. Again, 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 firstname.lastname@example.org. 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 Personal Data in order to fulfil your request. When processing your request, we may ask you for additional Personal Data to confirm your identity and for security purposes, before disclosing the Personal Data requested to 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 initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
- USE BY CHILDREN
We do not offer our products or services for use by children. If you are under 18, you may not provide us with any Personal Data without involvement of a parent or a guardian. We do not knowingly collect Personal Data from, and/or about children.
- CONTACT US
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 email@example.com.
You can read more about your rights here: https://ec.europa.eu/info/law/law-topic/data-protection_en
Last updated: May 22 2018