Company is a controller of the PII it processes in relation to its customers, vendors, service providers or partners. When Company processes PII on behalf of its customers, Company is a data processor under the GDPR, to the extent applicable. In that case, Company’s customer will be a data controller under the GDPR, and will be responsible to obtain the data subject’s consent or establish any other applicable lawful basis for processing and to ensure that data subjects can exercise their rights set forth in Section 10 below.
YOU ARE NOT LEGALLY REQUIRED TO PROVIDE US WITH PII, HOWEVER USE OF THE SERVICES REQUIRES THAT YOU PROVIDE PII. IF YOU CHOOSE TO WITHHOLD ANY PII REQUIRED IN RESPECT THEREOF IT WILL NOT BE POSSIBLE FOR YOU TO USE THE SERVICES. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN PLEASE DO NOT USE THE SERVICES.
“PII” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Information We Collect and How We Use It.
Summary: We collect personal data about our customers and their representatives and visitors of our Services. We also collect personal data included in publicly available sources.
We use PII to provide and improve our Services, and to meet our contractual, ethical and legal obligations.
In order to provide and operate our Services and provide services in connection therewith, we collect and process PII, including the following types of information:
Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (GDPR Article 6(1)(b)) OR Processing which is necessary for compliance with a legal obligation to which Company is subject (GDPR Article 6(1)(c)):
1.1 Your Contact Information. When you register to use the Services we ask you to provide PII, including: email address, full name, company/employer name and job title. We use this information to administer the Services, carry out our obligations, verify and carry out financial transactions, contact you for technical and administrative needs related to the Services, replying to queries and troubleshooting, detecting and preventing fraud, soliciting feedback, compliance and audit purposes, prevention of crime and identity theft and more.
1.2 Employee information. When you are employed by Company, we will collect information which we require and process in order to employ you and meet our obligations as an employer
1.3 Email Monitoring. We process PII in connection with our Services, including in particular the Solution, which will automatically monitor and reroute your sent and received emails and we may receive any PII included in such emails content, emails metadata, email addresses, IP addresses and shared files. Any emails and PII included therein retained on our servers are retained as temporary copies for communication and automatic real-time monitoring purposes and are thereafter deleted with our cache. This data is processed based on our relationship as processor for our clients (the controllers).
Processing which is necessary for the purposes of the legitimate interests pursued by Company or by a third party (GDPR Article 6(1)(f)) of providing efficient and effective Services to our customers, including:
1.4 Job Applicants’ Data. We collect PII from applicants seeking employment with Perception Point and submitting details through the Website, by e-mail or otherwise, including your full name, CV and all information therein, contact details (e.g. phone number, e-mail address, address), professional qualifications and previous employment history, any PII contained under the links to your portfolios, any PII under the free text for personal note. Job applicants’ PII is processed for the purpose of organizing and evaluating the hiring procedure during the recruitment of new employees, e.g. to assess applicants’ personal abilities, knowledge and skills prior to entering into the contract of employment or another contract of the Company and for HR management.
1.5 Third Parties. We sometimes supplement the PII with information that is received from third parties.
1.6 Usage information. When you use the Services, we automatically receive and record information from your device and browser, including without limitation information such as cookie information and statistics about your online/offline status, your IP address, geolocation data (including country and city), device identifiers, internet service provider, connection speed, search history, type of browser, your regional and language settings and software and hardware attributes. Our systems automatically record and store technical information regarding the method and nature of your use of the Services. An IP address is a numeric code that identifies your browser on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. The Company uses all of the PII identified in this Section in order to understand the usage trends and preferences of our users, including recent visits to our Services and how you move around different sections of our Services for analytics purposes and in order to make our Services more intuitive.
1.7 User When you send emails or other communications to the Company, we retain those communications in order to process your inquiries, respond to your requests and improve our Services.
1.8 Aggregate and Analytical Data. In the effort to produce insights regarding use of the Services in order to improve our services and develop and improve automated processes on our Services, we often conduct research on our users’ demographics, interests and behavior based on PII and other information provided to us. This research is compiled and analyzed on an aggregate basis, and we share this aggregate data with Company’s affiliates, agents and business partners and also disclose aggregated information in order to describe our services to current and prospective business partners or This aggregate information does not identify you or your customers or employees personally.
- Minors. If any of your data subjects (e.g. employees or customers) are minors aged 16 or under, you must obtain parental consent prior to using our Services. The Company will not knowingly contact or engage with children aged 16 or under without said parental consent.If you have reason to believe that a child has provided us with their PII, please contact us at the address given above and we will endeavor to delete that PII from our databases.
- Information sharing.
Summary: We transfer your PII to third parties who assist us in providing the Services. We have a contract with those third parties to govern their processing on our behalf. We may also transfer PII to comply with any obligations by which we are bound or to an investor or in connection with a merger or acquisition or similar transaction.
- Data Security. We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security. We retain your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
- Data Retention.
Summary: We retain PII only for as long as necessary to meet our legal and ethical obligations, which for different types of PII will be different periods.
7.1 Company will retain PII in accordance with its record retention policy. PII associated with our customers and business partners, will be retained for the duration of our engagement, and a period of seven years thereafter unless earlier requested to be deleted. PII associated with emails will be retained in accordance with the nature of the email- malicious emails will be retained for one year while “safe” emails are retained for two days. Company performs periodic reviews of our databases, and have established specific time limits for data retention, based on the criticality of the PII and the purposes of the data processing. We will also retain PII to meet any audit, compliance and business best-practices.
7.2 PII with respect to which Company is the processor will be deleted only on instruction of the controller, except where such data must be retained by us, in our judgment, as above.
- Rights of Data Subjects.
9.1 Right of Access and Rectification. Data subjects have the right to know what PII we collect about them and to ensure that such data is accurate and relevant for the purposes for which we collected it. Where we are controller, we allow data subjects the option to access and obtain a copy of their PII and to rectify such PII if it is not accurate, complete or updated. However, we may first ask data subjects to provide us certain credentials to permit us to identify their
9.2 Right to Delete PII or Restrict Processing. Data subjects have the right to delete their PII or restrict its processing. We may postpone or deny such requests if the PII is in current use for the purposes for which it was collected or for other legitimate purposes such as compliance with legal obligations.
9.3 Right to Withdraw Consent. Data subjects have the right to withdraw their consent to the processing of their Exercising this right will not affect the lawfulness of processing the PII based on consent obtained before its withdrawal.
9.4 Right of Data Portability. Where technically feasible, data subjects have the right to ask to transfer their PII in accordance with their right to data portability, if required pursuant to applicable law.
Where we are controller of your PII, you may exercise the above rights by sending a request to [email protected].
9.5 Right to Lodge Complaint. Data subjects also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of their
When data is provided by a Data Subject’s employer or organization, or through a Controller, such data subject rights will have to be effected through that customer or Controller. In addition, Data Subject rights cannot be exercised in a manner inconsistent with the rights of Company’s employees and staff, with Company’s proprietary and other rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property or internal documentation, or documentation which may affect Company’s rights cannot be accessed or erased or rectified by data subjects. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply.
Note that we may have to undertake a process to identify a Data Subject exercising their rights, and we will keep details of such rights exercised for our compliance and audit requirements. PII may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Data, depending on technical commercial capability. Such information may continue to be used by Company.
- Legal Justification and Consent to Processing.
- Your California Privacy Rights and Do Not Track Notices. California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding its disclosure of PII to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year.
Last Date Updated: May 15, 2023.
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