Hybrid Identity Protection

Privacy Policy

Last Updated: 20 January 2019

This privacy policy (“Privacy Policy”) governs how we, Semperis Ltd. (together, “Semperis” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“User”, “you”) such as in the following use cases:

 

(i) When you browse or visit our website, www.semperis.com, and/or https://www.hipconf.com/ (“Website”);
(ii) When you make use of, or interact with, our Website
a. When you request a demo or a free trial
b. When you register to a conference as part of the audience and/or as a speaker
c. When you download a whitepaper or click on “Get your copy”
d. When we process your job application
e. When you subscribe to the email list / newsletters / blog
f. When you contact us (e.g. customer support or send us an email or request)
(iii) When you attend a marketing event and provide Personal Data
(iv) When you exchange business cards with us
(v) When we acquire your Personal Data from third-party sources (such as lead-generation companies)
(vi) When we use the Personal Data of our service providers
(vii) When we use the Personal Data of our customers
(viii) When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn, etc) and we use the publically available information

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

 

Data we collect Why is the data collected and for what purposes? Legal basis (GDPR only) Third parties with whom we share your data Consequences of not providing the data
When you browse or visit our website
Cookies Marketing, analytics, analysis, market research, to improve our website Consent

Legitimate interest (e.g. essential cookies)

3rd party platforms such as for the following purposes:

· Salesforce

· Pardot

· Facebook

· Google

· LinkedIn

· Twitter

· Lead Landed

Cannot use or access some parts of the website
When you make use of, or interact with our Website
When you request a demo or a free trial
· Full Name

· Business email

· Company name

· Job title

· Phone number

· Number of employees

· Any other data you decide to provide/supply

 

 

· To provide the demo and/or the free trial Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. to provide a demo following your request)

3rd party platforms such as for the following purposes:

· Salesforce

· Pardot

· GoDaddy

· Microsoft

Cannot provide a demo and/or free trial
· To send marketing communications Consent Cannot send marketing communications
When you register to a conference as part of the audience and/or as a speaker
Audience:

· Full Name

· Business email

· Company name

· Job title

· Phone number

· Number of employees

· Any other data you decide to provide/supply

· To register you in the  conference in question

· To send you more information about the conference or reminders

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. to register you as a participant, to communicate with you, or to send a reminder)

3rd party platforms such as for the following purposes:

· Salesforce

· Pardot

· Eventribe

· GoDaddy

Cannot register you to the conference

Cannot attend to the conference

Cannot send you more information about the conference

Speaker:

· Full name

· Company name

· Title

· Email address

· Phone number

· Any other data you decide to provide/supply

· To process and evaluate your application

· To communicate with you regarding the details of the event

· To communicate with you via the conference organizers regarding your obligations, logistics, and other relevant information regarding the event

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to process your application submitted by you, to communicate with you where we have agreed that you will participate)

Cannot evaluate your application

Cannot participate as a speaker

Cannot communicate with you regarding the event

When you download a whitepaper
· Full Name

· Business email

· Company name

· Job title

· Phone number

· Number of employees

· Any other data you decide to provide/supply

· To provide the whitepaper in question

· To allow you to download it

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to process your request or to provide the whitepaper upon your request).

3rd party platforms such as for the following purposes:

· Salesforce

· Pardot

· GoDaddy

· Microsoft

Cannot receive the whitepaper(s)
· To send marketing communications Consent Cannot receive marketing communications
When we process your job application
· Full Name

· Email address

· Phone number

· CV

· Any other data you decide to provide/supply

· To process your job application

· To assess the candidate

· To communicate with you

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g. employment or consultant agreement)

Legitimate interest (e.g. to assess a candidate)

3rd party platforms such as for the following purposes:

· Microsoft

Cannot process your job application

Cannot assess you as a candidate

Cannot communicate with you

When you subscribe to the email list / newsletters / blog
· Full name

· Email address

· To add you to our mailing list

· To provide our blog and send marketing communications

Consent

Legitimate interest (e.g. in certain cases, sending you more information about Semperis in a B2B context is covered by the legitimate interest legal basis)

3rd party platforms such as for the following purposes:

· Salesforce

· Pardot

Cannot add you to our mailing list

Cannot read our blog

Cannot send you marketing communications

When you contact us (e.g. customer support or send us an email or request)
· First Name

· Last Name

· Company

· Business email

· Phone Number

· Severity Level (critical, high, low)

· Issue

· Any other data you decide to provide/supply

· To process and answer questions

· To provide support (e.g., to solve problems, bugs or issues)

· To customize your experience

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. process and respond to a question/query sent by you)

3rd party platforms such as for the following purposes:

· Salesforce

· Microsoft

Cannot assist you and respond your query

Cannot provide support

Cannot customize your experience

When you attend a marketing event and provide Personal Data
● Full Name

● Business email

● Company name

● Job title

● Phone number

● Number of employees

● Any other data you decide to provide/supply

· To establish a business connection/discussion

· To send marketing communications

Depending on the context, consent or legitimate interest (e.g. send you more information about Semperis in certain B2B situations) 3rd party platforms such as for the following purposes:

· Salesforce

· Pardot

Cannot establish a business connection

Cannot send you marketing communications

When you exchange business cards with us
· Full Name

· Business email

· Company name

· Job title

· Phone number

· Any other data you decide to provide/supply

· To establish a first business connection/discussion Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g. showing you certain products and features that you have shown an interest in, reply an email or message).

Legitimate interest (e.g. certain B2B discussions)

3rd party platforms such as for the following purposes:

· Salesforce

· Pardot

Cannot establish a business connection/discussion
When we acquire your Personal Data from third-party sources
Contact details · To establish a business connection

· To send marketing communications

Depending on the context, legitimate interest (B2B marketing), pre-contractual discussions or consent 3rd party platforms such as for the following purposes:

· Salesforce

· Pardot

Cannot establish a business connection

Cannot send you marketing communications

When we use the Personal Data of our service providers and suppliers
● Full name

● Email address

● Company name

● Phone number

● Any other data you decide to provide/supply

 

 

● To contact our service providers

 

● To process the order of the service

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. perform the contract, send contract-related communications)

3rd party platforms such as for the following purposes:

· Salesforce

· Pardot

 

 

Cannot communicate with you

Cannot process the order of the service

Cannot perform the agreement

When we use the Personal Data of our customers
● Full Name

● Business email

● Company name

● Job title

● Phone number

● Number of employees

● Any other data you decide to provide/supply

● To provide our products and services

● To perform the applicable agreement

● To communicate with our customers/clients

Processing is necessary for the performance of a contract to which our customer is a party.

Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).

Legitimate interest (e.g. send you contract-related communications)

3rd party platforms such as for the following purposes:

· Salesforce

· Microsoft

Cannot provide the services and/or our products

Cannot perform the agreement

Cannot communicate with you

When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn, etc)
● Full Name

● Business email

● Company name

● Job title

● Phone number

● Any other data you decide to provide/supply

● To reply and/or respond to your request or question

● To establish a first business connection/discussion

 

 

Depending on the context, legitimate interest (e.g. certain B2B marketing practices or replying your requests/questions), pre-contractual discussions (e.g. if you show interest in our products/services) or consent 3rd party platforms such as for the following purposes:

· Facebook

· Twitter

· LinkedIn

· YouTube channels

Cannot reply or respond to your request

Cannot establish a business connection

2. PERIOD OF STORAGE OF COLLECTED INFORMATION

Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request.  Please note that we may retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings. Read more in our cookie policy [https://www.hipconf.com/cookies-policy/]

3. HOW WE PROTECT AND STORE YOUR INFORMATION

  • Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  • Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

4. HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described in Section 1, we may share your information as follows:

  • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
  • Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

5. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

Access from Israel is covered by Israel’s Adequacy Decision and involves no data transfer issue. You can read more about this here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

Internal Transfers: We ensure transfers within the Semperis group will be covered by an agreement entered into by members of the Semperis group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to;

External Transfers:

  • Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.
  • Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States; or 
  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

6. YOUR RIGHTS 

The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

  • You have a right to access information held about you. Your right of access is normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading.
  • You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
  • The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
  • The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
  • The right to withdraw your consent. Please note that t there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
  • You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

 

You can exercise your rights by contacting us at GDPR@semperis.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

7. USE BY CHILDREN

We do not offer our products or services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

8. PUBLIC INFORMATION ABOUT YOUR ACTIVITY ON THE SERVICES

Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the Site or otherwise through the Services.

 

Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.

 

Please also remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

9. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

The Site may enable you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

10. LOG FILES

We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.

11. COOKIES AND OTHER TRACKING TECHNOLOGIES

Our Site may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Site and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

12. ANALYTIC TOOLS

  • Google Analytics. The Site may use a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
  • We reserve the right to use other analytic tools.

13. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our subscribers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.

14. OUR CALIFORNIA DO NOT TRACK NOTICE.

We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Site.

15. DELETION OF CONTENT FROM CALIFORNIA RESIDENTS. 

If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted.  If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law.  Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

16. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at GDPR@semperis.com.