- Information we Collect and Receive About You and How we Use It
- Data Retention
- Data Security
- International Transfer of Personal Information: Privacy Shield and Contractual Terms
- Rights with regard to Your Personal Information
- Contacting Akrivia If You Have Questions or Concerns
How we use your Information we collect and receive about You
We generally collect and process the following types of Personal Information:
Information You Provide us:
When using the Site, you may choose to provide us with certain Personal Information, such as your name, organization, email address, phone number, and other information. This information is used to
- communicate with you by responding to your requests, comments and questions,
- improve the Site and
- perform the Services provided by Akrivia.
- The GDPR legal basis for processing this information is
- the legitimate interest in communicating with you and improving our Site and
- the contractual obligation to perform the Services.
When you express an interest in obtaining additional information about the Services, the Site, Akrivia may ask you to provide your personal contact information, such as your name, email address, and phone number. This information is used to communicate with you by responding to your requests, comments and questions. The GDPR legal basis for processing this information is the legitimate interest.
As is true of most Websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site. The GDPR legal basis for processing this information is the legitimate interest in improving the relevance of our Site.
In case you choose to receive push notifications, in order to identify your device we collect its IMEI number.
Social Media Features:
Information Related to Data Collected for Our Clients Collection and Use in Providing the Services:
When acting as a service provider, Akrivia only collects information under the direction of its Clients. The Client Agreement governs the delivery, access, and use of the Services, including the processing of Personal Information and data submitted through Services accounts. The Client (e.g., your employer) controls their Platform and any associated client data. If you have any questions about specific Platform settings, the processing of Personal Information in the Platform, or its privacy practices, please contact the Client administrator of the Platform you use.
Client data will be used by Akrivia in accordance with the Client’s instructions, applicable terms in the Client Agreement, Client’s use of Services functionality, and as required by applicable law. Under applicable GDPR, Akrivia is a processor of Client data and Client is the controller.
Akrivia also uses other information in furtherance of our legitimate interests in operating our Services, the Site, and business.
How, and With Whom, Your Information Is Shared
Third Party Services:
At times, you may be able to access other Third Party Services through the Site, for example by clicking on links to those Third Party Services from within the Site. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies.
Information Shared with Our Service Providers:
We may share your information with third parties who provide services to us. These third parties are authorized to use your Personal Information only as necessary to provide these services to us. These services may include the provision of
- email services to send marketing communications,
- mapping services,
- customer service or support, and
- providing cloud computing infrastructure.
Information Shared with Our Sub-Processors:
We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control such as an email service providers to send emails on our behalf, mapping service providers, and customer support providers our “Sub-Processors”). We may need to share Personal Information with our Sub-Processors in order to provide Services to you. Unless we tell you differently, our Sub-Processors do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. Transfers to subsequent third parties are covered by onward transfer agreements between Akrivia and each Sub-Processor.
Information Disclosed Pursuant to Business Transfers:
Information Disclosed for Our Protection and the Protection of others:
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 also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to
- satisfy any applicable law, regulation, legal process or governmental request
- detect, prevent, or otherwise address fraud, security, or technical issues;
- respond to user support requests; or
- protect our rights, property, or safety. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
We require all third parties to respect the security of your Personal Information and to treat it in accordance with applicable laws. We do not allow third party service providers and Sub-Processors we share your Personal Information with to use it for their own purposes and only permit them to process your Personal Information for specified purposes in accordance with our instructions.
We will retain your Personal Information and the Personal Information we process on behalf of our Clients for as long as your account is active or as needed to provide Services to our Clients in accordance with Akrivia data retention policies, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You may request removal of your Personal Information at any time by contacting firstname.lastname@example.org.
The security of your Personal Information and our Clients’ information is important to us. We put in place appropriate technical and organizational measures to ensure your Personal Information is kept secure and protected from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. When you enter sensitive information (such as login credentials), we encrypt the transmission of that information using Transport Layer Security (TLS). We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. When we share your Personal Information with Sub-Processors or other third-party service providers, we base our selection on said parties having adequate safeguards in place that meet our data protection standards. We audit their compliance with such standards and incorporate contractual provisions ensuring compliance with
- such standards and
- applicable data privacy laws and regulations.
If you have any questions about security on Our Site, you can contact us at email@example.com.
As part of the Services, you may choose to opt-in to receive occasional email and other communications from us, such as communications relating to promotions. You may opt-out of receiving such communications at any time by using the “Unsubscribe” link found in such emails, or by emailing us at firstname.lastname@example.org In the context of us providing you marketing, we may analyze your preferences to make sure the information we provide you is relevant.
Rights with regard to Your Personal Information
We respect your control over your information and, in the event that you have provided Personal Information to us in your use of the Site, we will provide you with information about whether we hold any of your Personal Information. You may access, correct, or request deletion of your Personal Information by contacting us at email@example.com We will respond to your request within a reasonable timeframe.
When acting as a service provider of our Clients, Akrivia has no direct relationship with the individuals whose Personal Information is provided to Akrivia through the Services. An individual who is or was employed by one of our Clients and who seeks access to, or who seeks to correct, amend, object to the processing or profiling of, or to delete his/her Personal Information in the Platform, should direct his/her query to the HR department of the Client that uses the Platform and for which he/she works or used to work if he/she cannot make the appropriate changes via its access to the Platform provided by the Client.
If located in the European Economic Area (“EEA”), you have the following rights regarding your Personal Information we control
Right of Access:
You can request details of your Personal Information we hold. We will confirm whether we are processing your Personal Information and we will disclose additional information including the types of Personal Information, the sources it originated from, the purpose and legal basis for the processing, the expected retention period and the safeguards regarding data transfers to non-EEA countries, subject to the limitations set out in applicable laws and regulations. We will provide you free of charge with a copy of your Personal Information but we may charge you a fee to cover our administrative costs if you request further copies of the same information.
Right to be forgotten
At your request, we will delete your Personal Information if:
- it is no longer necessary for us to retain your Personal Information;
- you withdraw the consent which formed the legal basis for the processing of your Personal Information;
- you object to the processing of your Personal Information (see below) and there are no overriding legitimate grounds for such processing;
- the Personal Information was processed illegally;
- the Personal Information must be deleted for us to comply with our legal obligations.
We will decline your request for deletion if processing of your Personal Information is necessary:
- for us to comply with our legal obligations;
- for the establishment, exercise or defense of legal claims; or
- for the performance of a task in the public interest.
Right to restrict processing:
At your request, we will restrict the processing of your Personal Information if:
- you dispute the accuracy of your Personal Information;
- your Personal Information was processed illegally, and you request a limitation on processing rather than the deletion of your Personal Information;
- we no longer need to process your Personal Information, but you need your Personal Information in connection with the establishment, exercise or defense of a legal claim; or
- you object to the processing of your Personal Information (see below) pending verification as to whether an overriding legitimate ground for such processing exists.
We may continue to store your Personal Information to the extent required to ensure that your request to restrict processing is respected in the future.
Right to data portability:
At your request, we will provide you free of charge with your Personal Information in a structured, commonly used and machine-readable format, if:
- you provided us with your Personal Information;
- the processing of your Personal Information is required for the performance of a contract; or
- the processing is carried out by automated means.
Right to Object:
Where we rely on our legitimate interests (or that of a third party) to process your Personal Information, you have the right to object to this processing on grounds relating to your particular situation if you feel it impacts on your fundamental rights and freedoms. We will comply with your request unless we have compelling legitimate grounds for the processing which override your rights and freedoms, or where the processing is in connection with the establishment, exercise or defense of legal claims. We will always comply with your objection to processing your Personal Information for direct marketing purposes.
Right not to be subject to decisions based solely on automated processing – You will not be subject to decisions with a legal or similarly significant effect (including profiling) that are based solely on the automated processing of your Personal Information, unless you have given us your explicit consent or where they are necessary for the performance of a contract with us.
Right to withdraw consent: You have the right to withdraw any consent you may have previously given us at any time. In order to exercise your rights in this section we may ask you for certain identifying information to ensure the security of your Personal Information. To request to exercise any of the above rights, please contact us at firstname.lastname@example.orgWe will respond to your request within 30 days or provide you with reasons for the delay.
Usually, we will not charge you any fees in connection with the exercise of your rights. If your request is manifestly unfounded or excessive, for example, because of its repetitive character, we may charge a reasonable fee, considering the administrative costs of dealing with your request. If we refuse your request, we will notify you of the relevant reasons.
In so far as practicable, we will notify our Clients and third parties we have disclosed your Personal Information with of any correction, deletion, and/or restriction to the processing of your Personal Information. Please note that we cannot guarantee our Clients or other third parties will comply with your requests and we encourage you to contact them directly.
Please note that if you decide to exercise some of your rights, we may be unable to perform the actions necessary to achieve the purposes set out above or you may not be able to use or take full advantage of the Site.
Right to complain to a supervisory authority. If you are not satisfied with our response, you have the right to complain or seek advice from a supervisory authority and/or bring a claim against us in any court of competent jurisdiction in India.
You, or an authorized individual that we can verify is acting on your behalf, can exercise the applicable rights by contacting us using the contact details at the bottom of this Privacy Statement or by submitting your request through email@example.com
Contacting Akrivia If You Have Questions or Concerns
Effective Date: 01 Aug 2019.