Last updated September 20, 2017
Secureprivacy.ai (“Secure Privacy”) is committed to protecting the privacy of individuals who visit our websites and individuals whose personal information we may receive through the use of the Secure Privacy platform and related services provided to our Clients.
As a visitor to this website, your privacy remains under your control. We want you to have the information you need to make your own decisions regarding your privacy in the context of your interaction with Secure Privacy websites.
The use of personal data collected through our services shall be limited to the purpose of providing the services for which we have been engaged by our Clients.
1. Web sites covered
This Privacy Statement covers the information practices of Secure Privacy websites sites that link to this Privacy Statement, including http://www.secureprivacy.com; http://secureprivacy.com/; and https://secureprivacy.com. These websites are legally operated from Denmark.
Our websites may contain advertisements, banners and other links to non-secure privacy websites. We are not responsible for the information practices or the content of such other websites. We invite you to review the privacy statements of those other websites to understand how they use personal information.
2.1 Information you give us
We receive and store any information you enter on our Website and plugins or give us in any other way. This information may include (a) your name, email address, payment information (credit/debit card information), address of residence, phone number; (b) your IP address; (c) transaction-related information, such as when you use our SaaS platform or download our software plugins; and (d) information you provide us when you contact us for assistance.
2.2 Information your website users give you
SecurePrivacy.ai provides a solution for your website to record and document user consent given on that website. The recorded information includes:
- a screenshot of the web-page (in the domain of your website) where the user has given his/her consent;
- the user’s IP address and the associated location (country, city, state);
- the date the consent was given.
The recorded user consent and the associated personal data of the user can by accessed by you at any time via your Client interface.
While we provide appropriate technical means for collecting valid consent, it is your responsibility to make sure that collected consent is valid. For consent to be valid, it must be:
- freely given: the user must give consent by exercising genuine and free choice and must be able to withdraw that consent without detriment at any time, and to withdraw consent must be as easy as to give consent;
- specific (intelligible): every processing activity to which consent is given must be described in a clear, specific and precise manner;
- informed: users must be aware of your identity as the website owner who collects their consent;
- unambiguous: consent must constitute a statement or a clear affirmative action.
2.3 Information we collect automatically
Secure Privacy uses plugins and cookies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.
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.
When you accept the privacy notification, we gather information about your IP address, country, a screenshot of the web-page where you accepted the privacy notification, the date the consent was given, and what page you gave the consent on. We use this information only to document your consent to the displayed privacy statement. All such information is stored on servers operated by SecurePrivacy.Ai and located in the Netherlands. You can opt-out of your consent at any time from our website by clicking on the Secure Privacy widget in the lower right corner or by contacting us at [email protected].
2.4 Behavioral Targeting
We partner with third parties to manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this site and other sites in order to serve you advertising based upon your browsing activities and interests. If you wish not to have this information used for the purpose of serving you interest-based ads, you may opt-out by visiting our website on http://secureprivacy.wpengine.com and opt-out using the widget in the lower right corner.
There are different ways you can prevent your online activity being tracked. One of those is setting a preference in your browser that alerts websites you visit that you do not want them to collect certain information about you. This is referred to as a Do-Not-Track (“DNT”) signal. Please note that our websites may not recognize or take action in response to DNT signals from web browsers. At this time, there is no universally-accepted standard for what a company should do when a DNT signal is detected. In the event a final standard is established, we will assess how to appropriately respond to these signals.
2.5 Other Information Collected
You can log in to our Site using social identity providers such as Facebook, Google +, or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.
Our site also includes social media features, such as the Facebook Like button and widgets, such as the Share this button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing it.
2.6 Prospect User Data Supplementation
We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
3. Personal information we collect
We may use your information
(a) to deliver our website services and features desired by you (including any customization features requested by you);
(b) to improve our services for you;
(c) to personalize content and offers that may be of interest to you;
(d) to respond to your inquiries; and
(e) to fulfill your request for products or services. If provided, we may use your email address to contact you from time to time in the context of providing our products and services to you.
4. Use of personal information collected
We share information that identifies you only as described below and with subsidiaries we control that follow the same practices described in this Privacy Statement. We do not sell your personal information to third parties.
- Third Party Service Providers: We may retain other companies and individuals to perform functions on our behalf, such as sending email, removing repetitive and inaccurate information from customer lists, analyzing data, processing credit cards, and providing marketing assistance. They have access to personal information needed to perform their functions, but may not use it for other purposes. Currently we use the following Third Party Service Providers: WordPress and Jetpack by Automattic (US) for administering the website, Stripe (US) for payment processing, Typeform (Spain, EU) for collecting user input, MailChimp (US) and SendGrid (US) for sending service emails and newsletters, Google Analytics by Google (US) for gathering and processing analytical information regarding the use of our website, Intercom (US) for messaging. Some of these Third Party Service Providers are located and/or engage sub-contractors located outside the EU. Lawful basis for cross-border transfer of personal data to such non-EU Third Party Service Providers constitutes:
- self-certification of a service provider under the EU-US Privacy Shield scheme, or
- European Commission’s Standard Contractual Clauses (Model Clauses), or
- your explicit consent to the transfer of your personal data to a non-EU Third Party Service Provider, that has not yet implemented self-certification under the EU-US Privacy Shield scheme and with whom we do not yet have Model Clauses in place, collected and recorded by us on our website. You understand and accept that data protection legislation adhered to by such non-EU service providers may not be as protective as that in your country of residence.
By accepting this Privacy Statement, you consent to such use of your personal information by these Third Party Service Providers.
We may use new Third Party Service Providers if their processing of personal data is not in conflict with this Privacy Statement. We will notify you of our use of new Third Party Service Providers in advance in accordance with Section 10 “Changes to this Privacy Statement” hereof. By using our service after the advance notification period has elapsed, you accept such use of new Third Party Service Providers.
- Some of our pages utilize framing techniques to serve content to and from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to Secure Privacy.
- Scanning your website. During your registration with SecurePrivacy.Ai, you provide us the link to your website so that our service can scan it and determine a set of triggers for collecting user consent that can be selected by you. You acknowledge and accept that any personal data on the scanned website is processed by us solely for the purpose of setting up and configuring your user account and under your instructions.
- Protecting Others and Ourselves: We will disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and if we believe disclosure is necessary to protect our rights, property or safety of our customers or others. In particular, we may cooperate with law enforcement agencies in any official investigation and disclose your personal information to the relevant agency in doing so.
- Business Transfer: We reserve the right to transfer your personal information in the event Secure Privacy or substantially all of our assets are acquired. You will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
- In certain situations, Secure Privacy may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- With Your Consent: Other than as stated above, we will not disclose or provide your personal information to a third party without your explicit consent for us to do so.
Personal data collected on SecurePrivacy.ai is processed only in the context of our service for recording and documenting on your website user consents to your own separate processing activities, and it is your responsibility as a data controller to ensure that your processing activities to which users give their consent are compliant with applicable law. If we become aware that your processing activities are non-compliant with applicable law, we have the right to suspend or terminate the provision of our services to you, in which case we have no liability for any consequences of such suspension or termination.
5. Sharing of Personal Information Collected
- As a visitor to our website you can always choose not to provide us with personal information when requested, although it may be required for you to take full advantage of our website offerings.
- You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails. Customers, however, cannot opt out of receiving transactional emails related to their account.
Secure Privacy is built with privacy, security and reliability in mind, and has implemented reasonable security mechanisms to protect Secure Privacy’s Client Information and Client User Data that is maintained on Secure Privacy’ servers from loss, misuse and unauthorized access, disclosure, alteration and destruction. These security mechanisms include limited and password-protected areas, encrypted connections to and from Secure Privacy Servers, multiple firewalls and added security layers.
In addition, all persons authorised by us to process your personal data are under appropriate obligation of confidentiality.
The security of your personal information also depends on your protection of your account. Please do not disclose your website login credentials to unauthorized people. Also, be sure to sign off when finished using a shared computer.
However, please keep in mind that no security system is impenetrable. It may be possible for third parties to intercept or access Secure Privacy Client Information and Client User Data in spite of these measures. Secure Privacy cannot guarantee the security of your information and cannot be held responsible for unauthorized access to Secure Privacy client accounts.
We make great efforts to keep your information safe, but if we experience a security breach that exposes your data to risk, we will notify you, without undue delay, via email with details on the breach and the extent to which your data has been affected.
If you have any other questions about the security of our websites, please contact us using the contact information provided below in the “Contacting Us” section.
7. Client data
Secure Privacy collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
We will keep personal data we process on behalf of our Clients for as long as needed to provide services to our Clients. Secure Privacy may keep this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Notice and Choice: Individuals may submit personal information to our customers through the use of the website registration and login services we provide to our Clients. (Some of these services may have a notice that they are “powered by Secure Privacy”). This personal information is submitted with notice to, and the consent of, the individual user via identity providers’ permission screens, or voluntarily provided by the user at registration. Once Secure Privacy has successfully facilitated the transmission of personal information to a Client’s database that is not hosted by Secure Privacy, it is that Client’s responsibility to guard the personal information against unauthorized access or transmission.
Our Role in Processing and Protecting Client Data: As part of our Secure Privacy Customer Identity and Access Management Platform, we may receive and host on our Clients’ behalf such personal information and other data a customer may provide to us for hosting (collectively, “Client Data”). Our Clients are the data controllers of Client Data. As the processors of personal information on behalf of our customers, we follow their instructions with respect to the information they control. In doing so, we implement appropriate technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, personal information. We do not determine how our Clients use Client Data, and we will not access or disclose it except as directed or agreed to by our customers or required by law.
Accessing, Correcting, Amending, or Deleting Personal Information: If you are an individual seeking access to, or who would like to correct, amend, or delete your personal information which Secure Privacy may be storing on behalf of our Client, you should direct your request to the applicable Secure Privacy Client acting as the data controller for such information. Clients may access, and delete Client Data, including an individual record, via an application provider interface or API. If requested to remove/access data we will respond within 30 days. Following the deletion of personal information in a database we host, the related backup data will be deleted, generally within 10 days. Secure Privacy may keep this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
To assist our Clients and partners, and to market our services, we may disclose anonymous, aggregated, statistical information related to the use of our services by some or all of our Clients and their users. Such information will not contain any personal information or identify any customer or user of our services.
From time to time we may update this Privacy Statement. If we do, we will update the “effective date” at the top of the Privacy Statement. If we make an update with changes that are materially less restrictive regarding our use and disclosure of your information and/or provide for the use of new Third Party Service Providers, we will provide prior notice of such changes by posting notice on our website at the top of the then current Privacy Statement and send you an email with a link to such notice 30 days before the effective date of the update. Your continued use of this website or our service and/or continued provision of information to us will be subject to the terms of the then-current Privacy Statement.
9. Changes to this Privacy Statement
From time to time we may update this Privacy Statement. If we do, we will update the “effective date” at the top of the Privacy Statement. If we make an update with changes that are materially less restrictive regarding our use and disclosure of your information, we will provide prior notice of such changes by posting notice on our website at the top of the then current Privacy Statement 30 days before the effective date of the update. You should visit this page periodically to review any such changes to the Privacy Statement. Your continued use of this website or our service and/or continued provision of information to us will be subject to the terms of the then-current Privacy Statement.
10. Contacting Us
Questions regarding this Privacy Statement or about information practices of Secure Privacy should be directed by email to [email protected] or by mailing us.
Attn: Privacy, Skovdiget 3, 3460 Birkerod, Denmark