We are committed to protecting and respecting your privacy. This policy set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
WHAT TYPE OF PERSONAL DATA DO WE COLLECT AND USE?
Information we receive about you
You may provide us with information about you through a number of sources:
- our websites;
- any details provided to a VariGuard representative;
- if you enter into a competition and/or a promotion run by us;
- when corresponding with us by phone, email or otherwise; and
- personal data you provide when applying for a job advertised or submitting a speculative job application and/or C.V.
When you use our website we may automatically collect the following information which may include personal data:
- technical information including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- location information;
- information about your visit, including the full uniform resource locators (URLs) clickstream to, through and from our website (including date and time);
- products you viewed or searched for;
- photographs and generated content you might submit for competitions;
- page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); and
- methods used to browse away from the webpage.
We may also receive information about you from:
- your use of any of the other websites we operate or the other services we provide; and
- third parties (including for example, our licensees, subsidiary companies, third party suppliers and other interested partners) who we work closely with.
We may collect, use, store and transfer the information we receive about you.
In order to better understand our customers and to provide improved products and services to our customers we may combine publicly available data about you with personal data that we hold about you. The combination of both your personal data and other publicly available data may be used as statistical information and may also be used to send you information on an individual basis.
HOW DO WE USE THE INFORMATION COLLECTED?
VariGuard collects and uses your personal data because is it necessary for:
- the pursuit of our legitimate interests (as set out below);
- the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer; or
- complying with our legal obligations.
We also rely on consent as a legal basis for processing, including in relation to sending direct marketing communications to customers via email or text message. Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Our legitimate interests
The normal legal basis for processing your data, is that it is necessary for the legitimate interests of VariGuard , including:
- licensing our technology to customers;
- selling and supplying our products and services to our customers;
- promoting, marketing and advertising our technology, products and services;
- sending promotional communications which are relevant and tailored to individual customers;
- understanding our customers’ behavior, activities, preferences and needs;
- improving existing technology, products and services and developing new technology, products and services;
- complying with our legal and regulatory obligations;
- handling customer contacts, queries, complaints or disputes;
- fulfilling our duties to our customers, shareholders and other stakeholders;
- to assist in the investigation of suspected illegal or wrongful activity;
- to protect and defend our rights or property;
- to deal with any misuse of our website; and
- to sell, make ready for sale or dispose of our business in whole or in part, including to any potential buyer or their advisers.
WHO DO WE SHARE YOUR INFORMATION WITH?
We may share your personal data to third parties under the following circumstances:
- we may share your personal data with our licensees, subsidiary companies, group partners, third party suppliers and other interested parties to undertake the activities listed above or for such other purpose specified at the time of collection;
- we may share your personal data with our group companies and affiliates or third-party data processors who may process data on our behalf to enable us to carry out our usual business practices; and
- we may share your personal data with other companies and organisations to assist in the investigation of suspected illegal or wrongful activity.
Your credit card number, bank account and other financial information will not be revealed to anyone, except with your express permission, or if we are required to do so pursuant to credit card rules, processing a credit card payment, a court order or other legal process.
WHEN DO WE TRANSFER YOUR PERSONAL DATA OVERSEAS?
We may transfer, store and/or process the personal data we collect from you outside the European Economic Area (“EEA”). In particular, this may happen as some of our licensees, subsidiary companies, group partners, third party suppliers and other interested partners to whom we may transfer personal data may be located outside of the EEA. By submitting your personal data, you agree to this transfer, storing and/or processing.
While we will use our best efforts to ensure the security of your personal data, please be aware that we cannot guarantee the security of information transmitted over the internet.
VariGuard has in place security measures to protect against your personal data being accidentally lost, used or accessed in an unauthorised way, and altered or disclosed. Access to your personal data is limited to those third parties (i.e. licensees, subsidiary companies, group partners, third party suppliers and other interested partners to whom we may transfer personal data) who have a business need to know. All third parties are subject to a duty of confidentiality. We have established procedures to deal with any suspected or actual personal data breach and we will notify you and any applicable regulator of a breach, where we are legally required to do so.
VariGuard does not knowingly process or collect data or any other information from visitors under the age of 13 and does not provide information society services (ISS) directly to children. If we become aware that we are processing or collecting information from a visitor under the age of 13 without parental consent, VariGuard will remove and destroy such information. If you have any questions related to this section, please see our Contact Information below.
WHAT ARE YOUR RIGHTS UNDER APPLICABLE DATA PROTECTION LAW?
Your rights are as follows:
- the right to be informed about our processing of your personal data;
- the right to have incomplete personal data completed and the right to have your personal data corrected if the data we hold is inaccurate or out of date;
- the right to object to processing of your personal data and request that we stop sending you marketing information. You can also exercise this right at any time by contacting us on the Contact Information details set out below;
- the right to have your personal data erased (the “right to be forgotten”);
- the right to request access to your personal data (please refer to “Access to your Personal Data” section below);
You can exercise the above rights by contacting us using the Contact Information set out below.
Access to your Personal Data
You have the right to request a copy of the personal data that we hold about you. This is formally known as a “Data Subject Access Request”. We will not charge to deal with this request, but if the request is considered to be repetitive or clearly unfounded VariGuard may refuse it or charge a reasonable fee. You are entitled to one copy of the personal data we hold about you – if you request additional copies of your personal data, we may charge a reasonable fee for such copies.
When submitting your request, please provide proof of your identity. We will respond to your request as quickly as possible and within one month of receipt, unless the request is complex, in which case it could take a further two months.
We will only hold your data for as long as is necessary to pursue our legitimate interests (detailed above), provide our services, and protect our business. We use the following criteria to determine data retention periods of your personal data:
- your personal data will be retained by us for as long as necessary to pursue our legitimate interests
- your personal data will be retained by us for as long as necessary to deal with your queries;
- your personal data will be retained for as long as you might legally bring claims against us;
- your personal data will be retained for as long as is required by law or by a regulatory body; and
LINKS TO OTHER WEBSITES
This policy only applies to our websites. Our websites may, from time to time, contain links to and from other websites including (but not limited to) those of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
CONTACT INFORMATION AND OPT-OUT INFORMATION
You have the right to have your personal data corrected if it is inaccurate or incomplete. This will include the data that we and our partners (i.e. licensees, subsidiary companies, group partners, third party suppliers and other interested partners who we work closely with) hold on you. Please contact us if you would like to make corrections to any personal data you have provided to us, or if you no longer wish to receive future correspondence from us, or wish to withdraw your consent to sharing your personal data with others.
Our contact details are as follows: Seth@VariGuard.com
Please include your name and address so we are able to easily identify you.
The Data Protection Officer
c/o Seth Van Voorhees
VariGuard SmartGlass Inc.