Updated December 2020

Introduction

Welcome to the Riskonnect privacy policy.

Riskonnect respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy sets out the basis on which any personal data collected from you, or that you provide, will be processed by Riskonnect as a controller. It does not relate to our processing activities we carry out as a processor on behalf of our clients. Requests and queries relating to processing we conduct as processor should be directed to the relevant controller of your personal data.

We do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

We may share your personal data with any member of our group, which means our affiliates and subsidiaries (the “Riskonnect Group”). This privacy policy is issued on behalf of the Riskonnect Group so when we mention “Riskonnect”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Riskonnect Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.

Riskonnect Inc. is the controller and responsible for this website.

We have appointed a Data Privacy Committee (“DPC”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPC using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPC in the following ways:

Full name of legal entity:
Riskonnect Inc.

Email Address:
dpc@riskonnect.com

Postal Address:
Data Privacy Committee (DPC)
1701 Barrett Lakes Blvd, NW, Suite 500
Kennesaw, GA 30144
USA

If you are based in the UK, please use the following:

Postal Address:
Data Privacy Committee (DPC)
Riskonnect, Inc.
70 Gracechurch St. 2nd Floor,
London EC3V 0HR
United Kingdom

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. Any additions or modifications will be included in an updated privacy policy posted on our website.  This version was last updated on [DATE].

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.

Third-party links

This website 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 website, we encourage you to read the privacy policy of every website you visit.

2.The data we collect about you and how we use it

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed and cannot be ascertained form that information alone or in conjunction with other information (anonymous data).

You may provide personal data to us when you interact with us on behalf of your organization. We may collect, use, store and transfer different kinds of personal data about you and we will only use your personal data when the law allows us to. We have set out below, in a table format, a description of the data we collect, how we plan to use your personal data, and, for the purposes of data relating to individuals based in the EU or the UK, which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Your Identity and Contact Data such as your name, email address, office and cell phone number and LinkedIn URL.

Purpose

Legal basis

To register your organization as a new customer Performance of a contract with you
To manage our relationship with you which will include:

(a) answer queries and respond to your requests that you make to us;

(b) notify you of changes to our terms or privacy policy;

(c) handle user support requests

Necessary for our legitimate interests (to run our business, manage our relationship with you and keep our records updated)

Performance of a contract with you

Necessary to comply with a legal obligation

To manage event registration Performance of a contract with you

Necessary for our legitimate interests (to run our business and manage our relationship with you)

To provide our services to you Performance of a contract with you
To send you information about our products and services. Necessary for our legitimate interests (to keep you updated of products and services, to run our business)

Your Professional and Employment Data such as the name of your employer, job title, work history and experience in presenter bios collected for events, presentations, marketing collateral, and testimonials in connection with our business activities.

Purpose

Legal basis

To register your organization as a new customer Performance of a contract with you
To provide relevant content and products and services to you Performance of a contract with you

Necessary for our legitimate interests (to run our business, manage our relationship with you)

Your Financial and Transaction Data such as purchase history, financial details and payment information.

Purpose

Legal basis

To take payment and give refunds. Performance of a contract with you
To keep a record of any financial transactions with you Performance of a contract with you

Necessary for our legitimate interests (to run our business, manage our relationship with you and keep our records updated).

Your Technical Data about your device. This includes things like your IP address and approximate location information, login data, browser type and version, browser connection string, system settings, browsing actions and patterns, operating system and platform, and other technology on the devices you use to access our website.

Purpose

Legal basis

To administer and protect our business and this website. Necessary for our legitimate interest (for running our business, provision of IT and administration services, network security, growing our business and informing our marketing strategy).

Necessary to comply with a legal obligation.

To deliver relevant website content to you. Necessary for our legitimate interests (to define types of customers, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To improve our website and services. Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and services).

Your Usage Data about how you use our website as well as your preferences regarding related to products and services.

Purpose

Legal basis

To make suggestions and recommendations to you about goods or services that may be of interest to you. Necessary for our legitimate interest (to develop and grow our business, to develop our products/services and inform our marketing strategy).

Your Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences.

Purpose

Legal basis

To deliver relevant marketing content to you and measure or understand the effectiveness or the marketing we serve to you. Necessary for our legitimate interests (to study how customers use our services, to grow our business and to inform our marketing strategy)

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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 policy.

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 by law, or under the terms of a contract we have with you, 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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

Consent

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased services from us or where we think our services will be of interest to you and you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at dpc@riskonnect.com.

Where you opt out of receiving these marketing messages, we may still send you non-marketing related messages in relation to a purchase, service experience or other transaction that you have made.

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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.

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 information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

o   register to use our website;

o   request information regarding our services;

  • purchase or sell products or services on behalf of your organization;

o   request marketing to be sent to you;

o   request customer support;

o   sign up to an event such as a webinar or conference; or

o   give us feedback or contact us.

·         Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

·         Third parties or publicly available sources. We may also receive personal data about you from various third parties from whom we purchase personal data or collect from publicly available information. The personal data we collect from other sources includes identifiers, professional or employment-related information, education information, visual information, internet activity information, and inferences about preferences and behaviors. In particular, we collect personal data from the following sources:

o   Third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility, and verifying contact information; and

o   Other individuals at your organization who may provide us with your contact details for the purposes of obtaining services.

4.Disclosures of your personal data

We may share your personal data with various third parties as follows:

Service Providers:

We will share your personal data with our contracted service providers who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support, and data enrichment for the purposes and pursuant to the legal bases described above; such service providers comprise companies located in countries including USA, UK, Singapore, Australia, India, Germany, and Ireland.

Event Sponsors:

If you attend an event, conference, or webinar organized by us, or download or access an asset on our website, we may share your personal data with sponsors of the event. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not wish for your information to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned.

Customers with whom you are affiliated:

If you use our services as an authorized user of one of our customers, we may share your personal data with our customer responsible for your access to the services to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies.

Third party networks and websites:

With third-party social media networks, advertising networks and websites, so that we can market and advertise on third party platforms and websites.

Professional Advisers:

In individual instances, we may share your personal data with professional advisers acting as service providers, processors, or joint controllers – including lawyers, bankers, auditors, and insurers based in countries in which we operate who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your personal data.

Riskonnect Affiliates:

We share your personal data with the Riskonnect Group and companies that we acquire in the future after they are made part of the Riskonnect Group, to the extent such sharing of data is necessary to fulfil a request you have submitted via our websites or for customer support, marketing, technical operations, and account management purposes. Riskonnect affiliated companies are currently located in the United States, UK, and India.

We may also share personal data with 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 policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

5.International transfers

Your personal data may be collected, accessed, transferred to, and stored by us in the United States and by our affiliates and third parties disclosed above in section 4 that are based in other countries.

Whenever we transfer your personal data to these third parties, we ensure that the recipient of your personal data offers an adequate level of protection and security, for instance by entering into Standard Contractual Clauses or any other alternative mechanism for the transfer as approved by the European Commission under Article 46 of the General Data Protection Regulation or other applicable regulator.

Please contact us if you want further information on the specific mechanism used by us when transferring data to third parties.

6.Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.

7.Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

For individuals based in the EU or UK, in some circumstances you can ask us to delete your data see your legal rights in the EU and the UK below for further information.

In some circumstances we will anonymise 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.Your legal rights in the EU and the UK

If you are based in the EU or the UK, under certain circumstances, you have rights under data protection laws in relation to your personal data. 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:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • 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 using the contact details above.

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 could refuse to comply with your request in these circumstances.

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.

9.California Privacy Rights

California residents have the right to receive information that identifies any third parties with whom we have shared your personal data for that third party’s own marketing purposes with in the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting the Data Privacy Committee at dpc@riskonnect.com.

Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a Do Not Track (“DNT”) feature that signals to the websites that you visit that you do not want to have your online activity tracked. At this time, our website does not respond to DNT signals.  Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.

10.Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.