Ciber Digita may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are aware of any changes. This policy was last updated on June 30, 2020.
We collect and use certain information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“personal information”). When we do so we may be subject to various laws in the United States, including the California Consumer Privacy Act of 2018 (“CCPA”) and the General Data Protection Regulation (“GDPR”) which applies across the European Union, and we are responsible as “controller” of that personal information for the purposes of those laws.
Notwithstanding the foregoing, we do not market or promote our services to residents located in any country or jurisdiction other than the United States.
1. Personal Information We Collect About You. We may collect and use the following personal information:
|A. Identifiers.||Examples include: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||Examples include: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.|
|C. Protected classification characteristics under California or federal law.||Examples include: citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.|
|D. Commercial information.||Examples include: Services purchased, obtained, or considered.|
|E. Internet or other similar network activity.||Examples include: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|F. Professional or employment-related information..||Examples include: Current or past job history or performance evaluations.|
|G. Inferences drawn from other personal information.||Examples include: Preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.|
2. How Your Personal Information is Collected
We collect most of this personal information directly from you—in person, by telephone, text or email and via our website. However, we may also collect information:
4. How and Why We Use Your Personal Information
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons. In addition, your personal information may be subject to data protection laws that require us to only use your personal information if we have a proper reason for doing so, e.g.,:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests under applicable law. The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide services to you||For the performance of our contract with you or to take steps at your request before entering into a contract.|
|Conducting checks to identify our customers and verify their identity
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business.
|To comply with our legal and regulatory obligations.|
|Ensuring business policies are adhered to, e.g., policies covering security and Internet use.||For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures so we can deliver the best service to you.|
|Operational reasons, such as improving efficiency, training and quality control.||For our legitimate interests or those of a third party, e.g., to be as efficient as we can so we can deliver the best service for you.|
|To comply with our contractual obligations.||To comply with our legal obligations.|
|Ensuring the confidentiality of commercially sensitive information.||For our legitimate interests or those of a third party, e.g., to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations.
|Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, e.g., to be as efficient as we can so we can deliver the best service for you|
|Preventing unauthorized access and modifications to systems.||For our legitimate interests or those of a third party, e.g., to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations .
|Updating customer records||For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products.
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
|Marketing our services to:
⎯ existing and former customers;
⎯ third parties who have previously expressed an interest in our services;
⎯ third parties with whom we have had no previous dealings.
|For our legitimate interests or those of a third party, e.g., to promote our business to existing and former customers.|
|Credit reference checks via external credit reference agencies||For our legitimate interests or those of a third party, e.g., to ensure our customers are likely to be able to pay for our products and services.|
|External audits and quality checks.||For our legitimate interests or a those of a third party, e.g., so we can demonstrate we operate at the highest standards and to audit our accounts.
To comply with our legal and regulatory obligations
The above table does not apply to special category personal information as defined under the GDPR. If you are an individual whose personal data is subject to the GDPR, we will only process your special category information with your explicit consent.
5. Promotional Communications
We may use your personal information to send you updates (e.g., by email, text message, telephone or post) about our services. We have a legitimate interest in processing your personal information for promotional purposes (see above “How and Why We Use Your Personal Information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and, except as set forth in the section below titled “Who We Share Your Personal Information With,” we never sell or share it with other organizations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
6.Who We Share Your Personal Information With
We routinely share personal information with:
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.
May disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. The recipient of the information will be bound by confidentiality obligations.
7. Personal Information We Disclosed for a Business Purpose
In the preceding 12 months, we have disclosed the following categories of personal information to the following categories of third parties:
8. Sale of Personal Information
In the preceding twelve (12) months, we have not sold personal information for monetary value but we have disclosed the following categories of personal information for business and commercial purposes, which may constitute a sale of information under the CCPA, to the following categories of third parties:
We do not have actual knowledge that we sell the personal information of minors under 16 years of age.
9. Where Your Personal Information is Held
Information may be held at our offices and those of our service providers as described above (see above: “Who We Share Your Personal Information With”). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.
10. How Long Your Personal Information Will Be Kept
We will keep your personal information while you have an account with us, while we are providing services to you, or as otherwise set forth under Section 4 above for the purposes for which you provided such information to us. Thereafter, we will keep your personal information for as long as is necessary:
We will not retain your personal information for longer than necessary for the purposes listed above and as otherwise set out in this policy.
11. Transferring Your Personal Information Out of the EEA
If you are a resident of the European Union, then to deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
These transfers are subject to special rules under European and UK data protection law.
Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. If you would like further information, please contact us (see “How To Contact Us” below).
12. Your Rights and Choices
Your Rights Under the GDPR (if applicable).
|Right to Access||The right to be provided with a copy of your personal information (the right of access).|
|Right to Rectification||The right to require us to correct any mistakes in your personal information.|
|Right to be Forgotten||The right to require us to delete your personal information—in certain situations.|
|Right to Restriction of Processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data.|
|Right to Data Portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.|
|Right to Object||The right to object:
⎯ at any time to your personal information being processed for direct marketing (including profiling);
⎯ in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.
|Right Not to be Subject to Automated Individual Decision-Making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.
Your Rights Under the CCPA (if applicable).
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
|Disclosure of Personal Information We Collect About You||You have the right to know:
|Personal Information Sold or Used for a Business Purpose||In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
|Right to Deletion||Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
|Protection Against Discrimination||You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
13. Third Party Websites
14. Keeping Your Personal Information Secure
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We periodically test our systems and our security and privacy practices are subject to third party audit, which means we follow strict standards for information security. However, no method of transmission over the Internet, or method of electronic storage is one hundred percent secure and we cannot guarantee its absolute security. We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.
15. How to Exercise Your Rights
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly through our website, via email, or by phone, you will need to provide us with:
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
16. How to File a Complaint.
We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. You are entitled to file any claim or complaint before the relevant data protection authorities if the answer provided by NeoSystems does not meet your expectations.
17. How to Contact Us
Details for contacting us are shown below:
18. Do You Need Extra Help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).