THALES ESECURITY PRIVACY NOTICE

INTRODUCTION

Welcome to THALES ESECURITY Privacy Notice. In this Privacy Notice, we describe the information that we collect about you and how we use and disclose that information.

The protection of your personal data is of high importance to THALES ESECURITY, therefore THALES ESECURITY takes all reasonable care to ensure that your personal data is processed safely. When visiting our websites, you may share your personal data with THALES ESECURITY acting as data controller.

This privacy notice will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA RETENTION
  8. DATA SECURITY
  9. YOUR LEGAL RIGHTS

1. IMPORTANT INFORMATION AND WHO WE ARE

THALES ESECURITY is a leading global provider of data protection solutions. We respect your concerns about privacy. This privacy notice applies to the personal information we collect when you use our websites and when you use our Customer Services Support Portal and when you otherwise provide your personal information to us.

a. PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how THALES ESECURITY may collect and processes your personal data.

Our websites is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice carefully together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. This privacy notice may change from time to time, so please check the policy periodically for updates.

b. CONTROLLER

THALES ESECURITY is made up of Thales eSecurity Inc., Thales UK Limited and Thales Transport and Security (Hong Kong) Limited.

This privacy notice is issued on behalf of THALES ESECURITY so when we mention THALES ESECURITY, “we”, “us” or “our” in this privacy notice. THALES ESECURITY is the controller and responsible for purposes of this privacy notice.

Thales Group has appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

c. CONTACT DETAILS

You can contact Thales Group Data Protection Officer by sending an email to the following address: dataprotection@thalesgroup.com.

You have the right to lodge a complaint at any time to the competent data protection authorities. We would, however, appreciate the chance to deal with your concerns before you approach such authorities so please Contact us in the first instance.

d. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version of this privacy notice was last updated on April 29, 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

e. THIRD-PARTY LINKS

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy notice of every websites you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, title.
  • Contact Data includes email address and telephone numbers.
  • Profile Data includes your username and password, purchases or orders made by you on your company’s behalf, your companies’ interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our websites, products and services.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific websites feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data to (i) perform a contract we are about to enter into or have entered into with you, (ii) where necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests or (iii) to comply with a legal or regulatory obligation and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services) or download the technical or marketing material, applications, from our websites, or as otherwise set forth above.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by mail, phone, email or otherwise. This includes personal data you provide when you:

  • Use our websites
  • Create an account on our websites, partner portal, support portal or any other application or websites used to communicate with you or provide products or services.
  • Exchange email, text, phone, chat and other electronic messages with us.
  • Download marketing or technical material, download applications which provide dedicated non-browser-based interaction between you and us.
  • Purchase or license (or intend to purchase or license) our products or services, including maintenance and support
  • Sell or license (or intend to sell or license) products and services to us
  • Subscribe to receive our publications or marketing
  • Attend or register to attend sponsored events or other events at which we participate
  • Provide feedback
  • Enter a competition, promotion or survey

Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions, including your IP address, and patterns. We collect this personal data by using cookies, server logs and other similar technologies. A “cookie” is a file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. This allows us to recognize users and avoid repetitive requests for the same information. A “web beacon” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website. As a website visitor clicks through a website, a record of the action may be collected and stored. Other websites cannot read cookies from our websites. Most browsers will accept cookies until you change your browser settings to refuse them.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, including information provided by our Authorized Partners.

  • Identity and Contact Data from advertising service providers inside or outside the EU.
  • Identity, Contact, Profile, Usage, Technical, Marketing and Communications Data from analytics providers and data providers inside or outside the EU.
  • Identity Data, Contact Data, Marketing and Communications Data from our Authorized Partners.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the following lawful bases:

  • To perform the contract we are about to enter into or have entered into with you or to take steps at your request before entering into such a contract.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • To comply with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending certain direct marketing communications to you via email or text message in jurisdictions where consent is required by law. You have the right to withdraw consent to marketing at any time by contacting us at Contact us.

a. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We plan to use your personal data for the following purposes:

  • To manage a potential business relationship with prospects through marketing communications.
  • To make suggestions and recommendations to prospects about goods or services that may be of their interest.
  • To qualify leads and opportunities.
  • To prepare quotes, invoices and related documentation.
  • To deliver customers’ orders.
  • To manage payments, fees, charges and collect recover money owed to us.
  • Assist in the planning and coordination of services engagement and training.
  • To perform on our contracts.
  • To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
  • To manage our relationship with you which includes notifying you about changes to our terms or privacy policy.
  • To enable you to partake in a prize draw, competition or complete a survey and monitor your experience.
  • To deliver relevant website content, advertisements, measure or understand the effectiveness of the advertising we serve by informing our customers our marketing strategy, and creating and developing customer’s relationships and experiences.
  • To improve and keep our websites updated and relevant by using data analytics.
  • To provide access to training.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out above.

b. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. For more information on Cookies on please go to the Cookie Policy.

c. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

  • INTERNAL THIRD PARTIES

We may share your personal information with our affiliates of the Thales Group. Other companies in the Thales Group act as joint controllers.

  • EXTERNAL THIRD PARTIES

We do not sell your information to external third parties for their own marketing purposes. We share your information as follows:

  • Authorized Partners. We may provide information about you to carefully screened entities that work with us and require Identity Data and Contact Data for business development, marketing, selling and support purposes. Only trusted companies who require the use of such information for business purposes are given access to it. For more information about our authorized Partners please visit: https://www.thalesesecurity.com/partners.
  • Service providers. We may share your information with other third party service providers to assist us in bringing our websites, products and services, responding to your requests, and improving our websites and services. We also may engage third parties such as advertising agencies or marketing agencies to assist us in marketing our own products and services.
  • Professional consultant and advisers including public relations firms, market research and consulting companies, marketing agencies, lawyers, bankers, auditors, consultants and insurers.
  • Regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Many of the internal or external third parties identified in Section 5 are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. YOUR LEGAL RIGHTS

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us

a. NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

b. WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

c. TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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