1E Privacy Statement and Data Protection Policy

Introduction

Your privacy and trust are important to us and this Privacy Statement Statement provides important information about how 1E and its subsidiaries (“1E,” “we,” or “us”) handle personal information. This Statement applies to any 1E website, application, product, software, or service that links to it (collectively, our “Services”).

Please read this Statement carefully and contact our Data Protection Officer if you have any questions about our privacy practices or your personal information choices. It is important that you check back often for updates to this Statement. If we make changes we consider to be important, we will let you know by placing a notice on the relevant Services and/or contact you using other methods such as email.

This Statement was last updated on 22nd August 2017.

Below you will find helpful information about:

  1. Personal information
  2. The types of personal information we collect
  3. How we use personal information
  4. When we share personal information
  5. Where we store and process personal information
  6. How we secure personal information
  7. How long we keep personal information
  8. Your right to access and correct your personal information

1 - Personal information

1E is committed to the responsible handling and protection of personal information. Personal information means any information relating to an identified or identifiable natural person; an identifiable 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, online identifier or to one or more factors specific to the physical, physiological, genetic, economic, cultural, or social identity of that person. We collect, use, disclose, transfer, and store personal information only when needed to provide our Services and for our operational and business purposes as described in this Statement. We want to be clear about our privacy practices so that you can make informed choices about the use of your information, and we encourage you to contact us at any time with questions or concerns.

2 - The types of personal information we collect

We may collect personal information from you, for example, if you register for an event, request information, purchase or use our Software or Services, or request support. We may ask you to provide information such as your name, address, phone number and email address. Not all of the personal information 1E holds about you will always come directly from you. It may, for example, come from your employer, other organizations to which you belong, or a professional service provider. We also collect personal information from third parties such as our partners, service providers, and publicly available websites, to offer Services we think may be of interest and to help us maintain data accuracy and provide and enhance the Services.

In addition, our servers, logs, and other technologies automatically collect certain information to help us administer, protect, and improve our Services; analyse usage; and improve users’ experience. We share personal information with others only as described in this Statement, or when we believe that the law permits or requires it.

Occasionally we collect and process what may be considered sensitive personal information.

For example, if you purchase something from us or subscribe to our Services, we will collect payment information, such as financial or bank card information, and other information necessary for us to process the transaction. Some of our Services may ask you to share your precise geolocation so we can customize your experience and increase the accuracy of the Service. Information that is considered sensitive under applicable law will be handled in accordance with such laws.

3 - How we use personal information

We may process personal information for the following reasons:

Account setup and administration: We use personal information such as your name, email address, phone number, and potentially information about your technical environment  to set up and administer your account, provide technical and customer support and training and to send important account, subscription, and Service information.

Personalization: We may use personal information to deliver and suggest tailored content such as news, research, reports, and business information and to personalize your experience with our Services. Some of our Services will ask you to share your precise geolocation so we can customize your experience and increase the accuracy of the Service.

Marketing and events: We use personal information to deliver marketing and event communications to you across various platforms, such as email, telephone, text messaging, direct mail, and online. If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We may still send you important Service information related to your accounts and subscriptions.

Surveys and polls: If you choose to participate in a survey or poll, any personal information you provide may be used for marketing or market research purposes.

Research and development: We use personal information for internal research and development purposes and to improve and test the features and functions of our Services.

Chat rooms, messaging, and community and event forums: A number of our Services provide features including community and event forums for collaboration, peer connection, and information exchange purposes. Depending upon the Service, the personal information you choose to post, share, upload, or make available is public and visible to others who use those Services. You should never post or share any information that is confidential or about others unless you have permission to do so. These Services may have their own Terms of Use and, where appropriate, their own privacy statements. We moderate these Services for compliance with our Terms of Use.

Legal obligations: We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, or those of other persons.

4 - When we share personal information

1E shares or discloses personal information when necessary to provide Services or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. We may occasionally share non-personal, anonymized, and statistical data with third parties. Below are the parties with whom we may share personal information and why.

Within 1E: Our businesses around the world are supported by a variety of teams and functions, and personal information will be made available to them if necessary for the provision of Services, account administration, sales and marketing, customer and technical support, and business and product development, for instance. All of our employees and contractors are required to follow our data privacy and security policies when handling personal information. For a list of locations in which data may be processed you can visit the 1E website.

Our business partners: We occasionally partner with other organizations to deliver Services, provide content, or to host events, conferences, and seminars. As part of these arrangements we and our partners may collect and share information about you. 1E and our business partners will handle personal information in accordance with this Statement.

Our third-party service providers: We partner with and are supported by service providers around the world. Personal information will be made available to these parties only when necessary to fulfill the services they provide to us, such as direct marketing services, advertising and data analytics. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.

Third parties for legal reasons: We will share personal information when we believe it is required, such as:
To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence.

In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings)

To protect our rights, users, systems, and Services.

Recruitment: If you register with 1E or one of our Recruitment Partners in order to apply for employment, your personal information, including any sensitive personal information you provide, will be made available to appropriate people in the appropriate part of 1E in order to consider your application.

5 - Where we store and process personal information

1E is a global organization, and your personal information may be stored and processed outside of your home country. We take steps to ensure that the information we collect is processed according to this Privacy Statement and the requirements of applicable law wherever the data is located.
1E has networks, databases, servers, systems, support, and help desks located throughout our offices around the world. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within 1E or to third parties in areas outside of your home country. The areas in which these recipients are located will vary from time to time, but may include the United States, Europe, Canada, India, and other countries where 1E has a presence or uses contractors.

When we transfer personal information from the European Economic Area to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take measures to provide an appropriate level of data privacy protection. In other words, your rights and protections remain with your data. For example, we use approved contractual clauses, multiparty data transfer agreements, intragroup agreements, and other measures designed to ensure that the recipients of your personal information protect it. If you would like to know more about our data transfer practices, please contact us

6 - How we secure personal information

1E takes data security seriously, and we use appropriate technologies and procedures to protect personal information. Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements.

For example:

Policies and procedures

We have measures in place to protect against accidental loss and unauthorized access, use, destruction, or disclosure of data

We have a Business Continuity and Disaster Recovery strategy that is designed to safeguard the continuity of our service to our clients and to protect our people and assets

We place appropriate restrictions on access to personal information

We implement appropriate measures and controls, including monitoring and physical measures, to store and transfer data securely

We conduct Privacy Impact Assessments in accordance with legal requirements and our business policies

Training for employees and contractors

We require privacy, information security, and other applicable training on a regular basis for our employees and contractors who have access to personal information and other sensitive data

We take steps to ensure that our employees and contractors operate in accordance with our information security policies and procedures and any applicable contractual conditions

Vendors, we require, through the use of contracts and security reviews, our third-party vendors and providers to protect any personal information with which they are entrusted in accordance with our security policies and procedures

7 - How long we keep personal information

1E has implemented policies and rules relating to the retention of personal information. We only retain personal information for as long as we reasonably require it for legal or business purposes. In determining data retention periods, 1E takes into consideration local laws, contractual obligations, and the expectations and requirements of our customers. When we no longer need personal information, we securely delete or destroy it.

8 - Your right to access and correct your personal information

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information.

Access to personal information: If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).

Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal information if it is inaccurate or requires updating. You may also have the right to request deletion of your personal information; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by getting in touch with us

Marketing preferences: To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or visit the applicable email preference center. For other marketing preferences, you can use the “Contact Us” option within the relevant Service.

Filing a complaint: If you are not satisfied with how 1E manages your personal data, you have the right to make a complaint to a data protection regulator.

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