Privacy Policy

Effective as of June 1, 2018, Savvy Data Solutions Ltd (“SavvyData”) and its subsidiaries, (collectively, the “SavvyData  Group” or “we” or “us” or “our”) have set forth our Privacy Policy (“Policy”), as follows:

 

1. Introduction

This Policy details our commitment to protecting the privacy of individuals who visit our Website (“Website Visitors”), who register to use the products and services which we market for subscription (available at www.SavvyDataSolutions.com(the “Service(s)”), , or who attend or register to attend sponsored events or other events at which SavvyData participates (“Attendees”). For the purposes of this Policy, the term, “Websites”, shall refer collectively to www.SavvyData.com as well as the other websites that SavvyData may operate and that link to this Policy.

 

2. Limits to Scope of This Policy

When this Policy does not apply – Third party websites:

Our Websites may contain links to other websites. The information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.

 

When this Policy does not apply – Service Data:

With the exception of Account Information (as defined below) and other information we collect in connection with your registration or authentication into our Services, this Policy does not apply to our security and privacy practices in connection with your access to and use of the products and services which we market for subscription on our Websites (our “Services“). These security and privacy practices, including how we protect, collect, and use electronic data, text, messages, communications or other materials submitted to and stored within the Services by You (“Service Data”), are detailed in and governed by applicable agreement(s) between you and any agent of SavvyData relating to Your access to data and attendant Services (collectively referred to as the “Service Agreement”).

 

3. Information That You Provide To Us

 

Account and Registration Information:

We ask for and may collect personal information about you such as your name, address, phone number, email address, instant messaging ID, and credit card information, as well as certain related information like your company name and website name, when you register for an account to access or utilize one or more of our Services (an “Account”). We also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with Your Account.

 

If you sign-up for a free trial Account, you are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. A third-party intermediary is used to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.

We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal information or otherwise have the requisite consent to provide it to us.

 

Other Submissions:

We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including: participation in surveys, contests, promotions, sweepstakes, requesting customer support, or otherwise communicating with us.

 

Attendee Information:

We ask for and may collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which any member of SavvyData participates.

 

Device Information:

When you download and use our Services, we automatically collect information on the type of device you use, and operating system version.

 

4. Information That We Collect From You on our Websites

Cookies and Other Tracking Technologies:

We and our authorized partners may use cookies and other information gathering technologies for a variety of purposes. These technologies may provide us with personal information, information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites.

Web beacons, tags and scripts may be used on our Websites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.

 

Logs:

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.

 

Analytics:

We collect analytics information when you use the Websites to help us improve them, including through the use of cookies. We may also share anonymous data about your actions on our Websites with third-party service providers of analytics services.

 

6. How We Use Information That We Collect

General Uses:

We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote the Websites and the Services; (b) enable you to access and use the Websites and the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners (you can opt-out of receiving marketing communications from us by contacting us at Privacy@SavvyDataSolutions.com or following the unsubscribe instructions included in our email communications); (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Websites and the Services, and other illegal activities; (i) personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; and (j) for other purposes for which we obtain your consent.

 

Legal basis for processing (EEA visitors only):

If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we need the personal information to perform a contract with you (e.g. to provide you with our Services), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to use your personal information. If we process personal information in reliance on your consent, you may withdraw your consent at any time.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at Privacy@SavvyDataSolutions.com

 

7. Sharing Of Information Collected

Third-Party Service Providers:

We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

 

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.

 

Testimonials:

From time to time, we may post testimonials on the Websites that may contain personal information. We obtain Your consent to post Your name along with Your testimonial. If you wish to update or delete your testimonial, you can contact us at Privacy@SavvyDataSolutions.com.

 

Referrals:

If you choose to use our referral service to tell a friend about our products and services, we will ask you for your friend’s name and email address. You must only provide your friend’s name and email address if you have a reasonable belief they will not object to us contacting them. If you do, we will automatically send your friend an email inviting him or her to visit the Websites and will store this information for the purpose of sending this initial email, tracking the success of our referral program and other marketing activities. Your referral may contact us at Privacy@SavvyDatasolutions.com to request that we remove his/her information from our database.

 

Community Forums:

The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas“). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your personal information from an Interactive Area, contact us at Privacy@SavvyDataSolutions.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

 

With Your Consent:

We may also share personal information with third parties when we have your consent to do so.

 

8. International Transfer of Personal Information

International transfers:

We store personal information about Website Visitors and Subscribers within the EEA, the United States and in other countries and territories. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which SavvyData has operations.

 

If you are visiting our Websites from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.

 

Privacy Shield Frameworks:

SavvyData abides by and has certified adherence to the principles of the EU-U.S. and Swiss-U.S. Privacy Shield frameworks as set forth by the U.S. Department of Commerce. For more information on the Privacy Shield frameworks.

 

9. Data retention

Where SavvyData is the data controller of personal information (for example, personal information relating to Website Visitors, Attendees and individuals who register to use our Services), then we retain the personal information we collect where we have an ongoing legitimate business need to do so (for example, to provide you with our Services, to enable your participation in an event, and to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

If your personal information is processed within a Subscriber’s Service Data, we will process the personal information for as long as we are instructed to do so by the relevant Subscriber that is the data controller of the Subscriber Service Data.

 

10. How to exercise your data protection rights

You have certain choices available to you when it comes to your personal information. Below is a summary of those choices, how to exercise them and any limitations.

Correcting, updating and removing your information:

An individual who seeks to exercise their data protection rights in respect of personal information stored or processed by us on behalf of a Subscriber of ours within the Subscriber’s Service Data (including to seek access to, or to correct, amend, delete, port or restrict processing of such personal information) should direct his/her query to our Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove the personal information, we will respond to their request to Privacy@SavvyDataSolutions.com within thirty (30) days. We will retain personal information that we process and store on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers.

 

Accessing and updating or deleting your information:

Our Services and related documentation on our EU Data Protection site give agent and end-users the ability to access, update and delete certain personal information from within the Service. For example, you can access your agent or end-user profile and make updates to your personal information. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

 

Request that we stop using your information:

You may request that your personal information no longer be accessed, stored, used and otherwise processed where you believe that we do not have the appropriate rights to do so. Where you gave us consent to use your personal information for a limited purpose, you can contact us at Privacy@SavvyDataSolutions.com to withdraw that consent. You can also opt-out of our use of your personal information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request.

 

Opt-out of communications:

We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request to Privacy@SavvyDataSolutions.com. You may opt-out of receiving promotional communications from us by using this unsubscribe link within each email. Even after you opt-out from receiving promotional messages from us, if you are an Agent, then you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings.

 

Other data protection rights:

If you wish to exercise any other data protection rights that are available to you under your local data protection laws (such as the right to data portability or to data restriction) then please send your request to
Privacy@SavvyData.com. We will action your request in accordance with applicable data protection laws.

 

You have the right to complain to your local data protection authority if you are unhappy with our data protection practices. Contact details for data protection authorities in the European Economic Area are available here.

 

11. Children’s Personal Information

We do not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through the Websites or Services, please contact us at Privacy@SavvyData.com, and we will use commercially reasonable efforts to delete that information.

 

12. Business Transactions

We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge. If we do, we will inform them of the requirement to handle your personal information in accordance with this Policy.

 

13. Changes to This Policy

This Policy may be updated from time to time to reflect changing legal, regulatory or operational requirements. We encourage you to periodically review this page for the latest information on our privacy practices.

 

If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective. If we are required by law to do so, we will seek your consent prior to those material changes becoming effective.

 

If you do not accept any part of this Policy, please discontinue use of the Websites and the Services.