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 1. Home
 2. Legal & compliance
 3. Website privacy policy


WEBSITE PRIVACY POLICY



Download PDF

We are Egress Software Technologies Limited, part of the Egress Software
Technologies Group. More information about us and our group can be found
at https://www.egress.com/about.

This privacy policy sets out details about the information that we collect when
you use or browse www.egress.com, our partner portal, or the apps that we make
available to access our services (collectively, our Sites). By using our Sites
you confirm that you accept this policy. If you do not, then please do not use
them.

This policy describes:

 * the information we collect and how we get it
 * how we use that information
 * who we may share it with and why
 * where we may transfer and process it
 * what you need to do if you provide information to us about others

If you have any questions we would be happy to answer them. Just get in touch at
DPO@egress.com.

This policy was last updated on 26 April 2021.


THE WAY WE TALK ABOUT THE INFORMATION WE COLLECT THROUGH BROWSING OUR SITES

Data type

How we describe it

Personal Contact Information

Information about you that you provide to us, or that we obtain such as:

§  name, address, phone number, email address and other contact details

§  any permissions, consents or preferences that you give us

§  how you use our Sites (where you can be identified)

§  information that we obtain from third parties that may be linked to you, your
employer or your organisation

Third-party data

Information that you provide about a third-party (e.g. a prospect, business
contact or business with a need for a product or service that we provide or
sell).

Website data

(i) Usage statistics, system logs, performance and security data, feedback data
and aggregated data about how our Sites are used (e.g. performance counters,
access logs, metrics, associated metadata, unique identifiers for devices,
technical information about the devices used, the network, operating system and
browser). (ii) data identified as malicious (e.g. malware infections,
cyberattacks, unsuccessful security incidents, or other threats).

 


THE INFORMATION WE COLLECT AND HOW WE GET IT

We collect information about you in a number of ways. We may combine the
information that we receive from these various sources with other information
that we collect or receive. We set out further below how we use this
information.


SECURITY

The security and confidentiality of your personal information is very important
to us. We have implemented commercially reasonable technical and organizational
safeguards to appropriately protect your personal information against
accidental, unauthorized, or unlawful access, use, loss, destruction or damage.
The measures that we utilize are administrative--[such as the training of
employees on privacy and information security-related activities],
technical--[such as pseudonymization or encryption techniques, and network
firewalls], and physical--[such as locks and video surveillance].

We limit access to your personal information 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. 

Still, no system can be guaranteed to be 100% secure. If you have questions
about the security of your personal information, or if you have reason to
believe that the personal information that we hold about you is no longer
secure, please contact us immediately as described in this Privacy Notice.

From

How we obtain or receive it

Examples of the types of information

You

§  filling out forms on our website or apps

§  contacting us

§  taking part in our competitions or promotions

§  attending our webinars. We may record our webinars, and therefore your
participation in them. We will also keep a record of your attendance

§  registering to use any services that we provide (including our partner
portal)

§  uploading information to our partner portal

§  Personal contact information

§  Website data

§  IP address (this may not always be personal to you – e.g. where using shared
networks)

§  Third-party data

Third parties

§  publicly accessible records

§  third-party data providers who we purchase information from (e.g. name, email
address, telephone number, job role, employer, market sector/industry, country)

§  making use of our Sites

§  filling out forms on our Sites and providing information about you

§  contacting us and providing information about you

§  government and law enforcement agencies

§  filling out forms on websites or webforms that we host on behalf of a
third-party

§  open data and public records

§  records provided by third-parties

§  information sent by or received from third-parties

§  Personal contact information

§  Website data

§  Third-party data

General use of our Sites

§  Accessing and using our Sites

§  Cookies

§  Personal contact information

§  IP address (this may not always be personal to you – e.g. where using shared
networks)

§  Website data

IP address

§  when you visit our Sites we will record your IP address.

§  your IP address may be kept in log files or matched against public or
proprietary IP address databases to provide us with information about your
visit. This may identify the organisation to whom the IP address is registered
(and may in some cases enable us to identify you)

§  IP address

§  Personal contact information


 


HOW WE USE THE DATA THAT WE COLLECT

We use the personal contact information and website data in each of the
following ways.


RELATIONSHIP MANAGEMENT

What we use it for

Our reasons

Our lawful basis where you are an individual

Our lawful basis where you are a business

Information type

Manage, track and develop our relationship with you

Processing to complete any pre-contract processes that you request.

Performance of contract, Legitimate interests

Legitimate interests

Personal contact information

To ensure that we have a productive relationship where we are able to meet user
needs and respond to them both proactively and reactively. This is core to our
business and forms the cornerstone of success. If we were unable to process
personal data for this purpose, our business would cease to function properly.
If you participate in the Egress Partner Programme and we were unable to process
this information, we would be unable to work effectively with you in pursuing
the collective aims of that programme.

Legitimate interests

Legitimate interests

Personal contact information, website data

To contact you in relation to potential sales opportunities, and to understand
you and your employer or organisation better through the use of data that we
receive from third party providers.

Legitimate interests

Legitimate interests

Personal contact information, website data

We may use your information to create reports or profiles (both of you and the
organisations or third-parties that you provide information about) for marketing
and analytics purposes.

Legitimate interests

Legitimate interests

Personal contact information, website data


 


DELIVERY OF SERVICES

What we use it for

Our reasons

Our lawful basis where you are an individual

Our lawful basis where you are a business

Information type

Ensure our Sites are functioning properly

To ensure that we can provide the access to our Sites.

Legitimate interests

Legitimate interests

Personal contact information, website data

To provide guidance on using our Sites or other support.

Legitimate interests

Legitimate interests

Personal contact information, website data

Respond to and resolve complaints, queries and requests

To respond to your queries, complaints and to ensure that you are able to use
our Sites appropriately. This may involve the recording of calls that you make
to our support desks or sales teams for training and monitoring purposes. We use
a ‘follow-the-sun’ support structure which means that calls may be answered and
recorded outside the country you are located in depending on the time of your
call and the support staff responding.

Legitimate interests

Legitimate interests

Personal contact information, website data, Third party data

Alert you to issues or updates to our partner portal

To ensure that you are presented with relevant information if we change aspects
of our partner portal and decide to alert users to those changes.

Not applicable

Legitimate interests

Personal contact information, website data

Service information by electronic means

If you use our partner portal we may send, or otherwise display, to you
information about the portal (e.g. how you use it, how you could do so more
efficiently, faults, issues, updates or notices of times when it will not be
available).

Not applicable

Legitimate interests

Personal contact information, website data


 


DELIVERING ON CONTRACTUAL OBLIGATION AND EXERCISING RIGHTS

What we use it for

Our reasons

Our lawful basis where you are an individual

Our lawful basis where you are a business

Information type

Make and manage payments made by, or due to, you, your employer or your
organisation

Processing to achieve this purpose may take place both pre and post contract
agreement (e.g. initial subscription payment and renewals).

Performance of contract, Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data

Meet and perform our audit obligations

We recognise that processing may be required in order for our own compliance
purposes (e.g. to ensure that our financial processes are accurate and working
properly).

Legitimate interests, Legal obligation

Legitimate interests, Legal obligation

Personal contact information, website data, Third-party data

Recover money owed to us or other companies in our group

To ensure that payments are both made and timely.

Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data

Service information by electronic means

If you use our partner portal we may send, or otherwise display, to you
information about the portal (e.g. how you use it, how you could do so more
efficiently, faults, issues, updates or notices of times when it will not be
available).

Not applicable

Legitimate interests

Personal contact information, website data

Exercising our rights

We may need to process certain information (including personal data) in order to
exercise or enforce our rights under this and any other relevant policies.

Legitimate interests, Legal obligation

Legitimate interests, Legal obligation

Personal contact information, website data, Third-party data

Progressing opportunities provided by you through our Partner Portal

If you use our partner portal, once you have provided Third-party data through
it to us, we will use it to progress the opportunity (if any) including to
qualify the Third-party data as a lead and, where possible, close it out to a
sale. Third-party data is held by us as an independent controller, not a joint
controller with you.

Not applicable

Legitimate interests

Personal contact information, website data, Third-party data

Responding to and actioning any request by you in exercising your legal rights
in relation to your personal data

Processing may be required to provide confirmation of information to you (e.g.
if you make a data subject access or data portability request) or in order to
action a request that you make (e.g. correction, deletion, erasure or
restriction).

Legitimate interests, Legal obligation

Legitimate interests

Personal contact information, website data, Third-party data



LEGAL AND REGULATORY RISK MANAGEMENT

What we use it for

Our reasons

Our lawful basis where you are an individual

Our lawful basis where you are a business

Information type

Detect and prevent crime

To ensure that we and our group can both detect and report criminal activity.

Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data

Manage risk for us, our group and users

To ensure that we and our group can manage legal and regulatory risk and do so
in the most appropriate and compliant manner.

Legitimate interests, Legal obligation

Legitimate interests, Legal obligation

Personal contact information, website data, Third-party data

Obey our or our group’s legal obligations

To ensure that we and our group can manage legal and regulatory risk and
requests in the most appropriate and compliant manner. This may include adapting
the way we and our group operates or engages to meet new or future obligations.

Legitimate interests, Legal obligation

Legitimate interests, Legal obligation

Personal contact information, website data, Third-party data

Keep our records accurate and up-to-date

Processing to ensure we meet our obligations in respect of data accuracy (this
may include acting in response to your notifications).

Legitimate interests, Legal obligation

Legitimate interests, Legal obligation

Personal contact information, website data, Third-party data

Run our and our group’s businesses in an efficient and proper way

We use shared systems, activities, suppliers and sub-processors in order to help
manage legal and regulatory risk within our group, and to operate in a way that
ensures quality, consistency and security of service delivery.

Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data


 


INNOVATION AND SYSTEM DEVELOPMENT

What we use it for

Our reasons

Our lawful basis where you’re an individual

Our lawful basis where you’re a business

Information type

Develop new systems, features, functionality and ways to meet user needs

We have a legitimate interest to understand how our Sites are used, and to look
at areas where user needs could be met either as new functionality, or in
improved ways.

Legitimate interests

Legitimate interests

Personal contact information, website data

Study how users are using our Sites

We have a legitimate interest to understand how our Sites are used, and how
users benefit from the services that we provide to them.

Legitimate interests

Legitimate interests

Personal contact information, website data

Test new products and services

We have a legitimate interest in ensuring that prior to being launched,
functionality operates in a secure and efficient manner.

Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data

Show you the right Sites

To ensure that you enter into any contractual relationship with the right
company in our group. This also enables us to present content relevant to that
jurisdiction where appropriate.

Legitimate interests

Legitimate interests

Personal contact information, website data, IP address, Third-party data

To create anonymous reports and statistics

We have a legitimate interest in understanding market risks, trends and
activities and, where relevant, utilising the anonymous insights that we can
gain from our Sites in the provision of both internal and publicly available
reports, blogs and other communications.

Legitimate interests

Legitimate interests

Personal contact information, website data, Third-party data


 


MARKETING AND PROMOTION

What we use it for

Our reasons

Our lawful basis where you’re an individual

Our lawful basis where you’re a business

Information type

To enable your participation in competitions and promotions

Where you have elected to take part, we will process your information in order
to enable you to participate.

Consent

N/A

Personal contact information, website data

To develop and carry out marketing activities

We have a legitimate interest to conduct marketing, promotional and other
advertising activities in order to grow our brand, and the awareness of our
products and services. We may use information that we source from third-party
data providers to contact you where this is permitted by law. We may also use
information we collect about the domain of your email address (e.g. about your
employer or organisation, it’s sector/industry) or that we can relate back to
you (e.g. through cookies) about the products you’re interested in to tailor our
communications and make them more relevant to you.

 

Legitimate interests, Consent

Legitimate interests

Personal contact information, website data

We may use information that we hold about you (or if you are a business, your
users) to send information about our and our group companies’ products and
services. This may be by email or other electronic means available to us in the
future. We may use other information available to us in order to tailor our
communications. If you are an individual in most circumstances we wi’ll only do
this if we have your consent but there may be some situations where we have a
legitimate interest in doing so (e.g. where you complete a purchase through our
online ecommerce platform, or where otherwise permitted in line with regulatory
and industry guidelines in respect of B2B marketing activity).

If you have given your consent, you can withdraw this at any time, or if we are
reliant on our legitimate interests for sending you marketing you can object. In
either case, just let us know using the details
at www.egress.com/legal/your-rights.  If you have received a direct marketing
emails from us and no longer wish to do so, the easiest way to let us know is to
click on the unsubscribe link at the bottom of our group marketing emails.  If
you receive a personal marketing email from one of our Sales team, just respond
to let them know you do not want to receive any more communications.

We partner with a third party to manage our advertising on other sites. Our
third party partner may use cookies or similar technologies in order to provide
you advertising based upon your browsing activities and interests. If you wish
to opt out of interest-based advertising click the links below. Please note you
will continue to receive generic ads.

 * Digital Advertising Alliance (DAA)’s self-regulatory opt-out page
   (http://optout.aboutads.info/) and mobile application-based "AppChoices"
   download page (https://youradchoices.com/appchoices)
 * European Interactive Digital Advertising Alliance (EDAA)'s consumer opt-out
   page (http://youronlinechoices.eu)
 * Network Advertising Initiative (NAI)’s self-regulatory opt-out page
   (http://optout.networkadvertising.org/).


SUBSCRIBING TO OUR SERVICES

If you purchase a paid-for subscription to our services through our Sites then
limited information about your purchase may be shared with relevant payment
service providers.  Information may be used by those providers in accordance
with their own privacy policies and terms and conditions in order to complete
your purchase, manage your relationship and any future renewal, and to comply
with applicable law.


IF YOU PROVIDE US WITH INFORMATION ABOUT OTHERS

If you or your business provide information to us about another person or
business (such as Third-party data) you must make sure you have the right and
permission to do so (e.g. by providing appropriate data collection notices to
individuals who are the subject of Third-party data). We are reliant on this in
order to receive and process the information you provide. By providing it, you
confirm that you do.

Ownership of Third-party data: Once you have uploaded Third-party data to our
partner portal, we hold that information (including any personal data within it)
as a controller. You may yourself be an independent controller, not a joint
controller, of some or all of that Third-party data. We are therefore free to
use Third-party data for our own purposes and to determine when, how and where
it is processed (subject to compliance with relevant data protection laws).


WHO WE MAY SHARE YOUR INFORMATION WITH, AND SENDING INFORMATION OUTSIDE THE
COUNTRY YOU ARE LOCATED IN

Delivery of our Sites: Details of the subcontractors used in the provision of
our Sites, marketing activity, prospect and customer relationship management,
and in the delivery of our services can be found through the subcontractor page
available at www.egress.com/legal/subcontractors. We share your information with
these third-parties to help with our business activities and delivery of our
services. They are only authorised to use your personal information as necessary
to provide the services to us that we request from them and must abide by data
privacy and security obligations set out in applicable law.

Where any transfer outside of the country or region that you are located in
(e.g. the European Economic Area (EEA), the United States or the UK) occurs, we
will ensure that any such transfer or processing is subject to appropriate legal
and technical safeguards with our subcontractors in line with local law
requirements.

Provision of Partner Portal: We use Salesforce, Inc. to provide both our Portal
and the CRM system that information provided through it is stored on. Details
about Salesforce’s approach to privacy

Transfer of rights: We reserve the right to transfer our obligations, rights and
permissions in personal contact information and website data to any organisation
to which we may transfer our business or assets (including if we, or a relevant
part of us or our assets, are proposed to be purchased or acquired by a third
party).

Selling your information: We will not, and do not, sell or rent your information
to third-parties for: (i) valuable consideration (as defined in the California
Consumer Privacy Act) or for their direct marketing purposes; or (ii) monetary
consideration for the person to license or sell it to additional persons (as
defined in Nevada Senate Bill 220). Your information may be shared with third
parties as set out above for our business purposes, including the provision of
services to you and/or your organisation or employer.

Applicable law: We reserve the right to disclose personal contact information
and website data in order to comply with national, EU or Member State law to
which we’re subject, including to meet national security and law enforcement
requirements. You can find out more on our approach here.


WHAT WE NEED YOU TO DO

We need to make sure that the information that we hold about you is accurate,
up-to-date and still relevant. As a result, we need you to tell us promptly if
there are any changes to the information that you provide by letting us know
at DPO@egress.com.


HOW LONG WE WILL KEEP YOUR INFORMATION FOR

We will keep information in accordance with our data retention policies
available at www.egress.com/legal, including to maintain records required for
legal or regulatory reasons, to show that we complied with our contractual
obligations, to respond to any complaints or queries, and for research and
statistical purposes.


YOUR RIGHTS AS AN INDIVIDUAL

As an individual user of our Sites, you may have certain rights by law in
respect of the personal data that we hold about you. These rights may not always
apply as your location and the basis on which we’re processing your personal
data may affect their availability. You can find out more information about them
and our Data Protection Officer at www.egress.com/legal/your-rights.

If you ever have a complaint relating to the delivery of our services, or our
processing of your personal information, you can find details on how to raise
this in our Complaints Policy at www.egress.com/legal.


PRIVACY SHIELD

We participate in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and have
self-certified to the U.S. Department of Commerce our adherence to the Privacy
Shield Principles for all personal information received from countries in the
European Economic Area, Switzerland, and the United Kingdom in reliance on the
Privacy Shield. To learn more about Privacy Shield, visit the Privacy Shield
website at www.privacyshield.gov/list.

Under Privacy Shield, we are responsible for the processing of personal
information we receive and subsequently transfer to a third party acting for or
on our behalf. We are liable for ensuring that the third parties we engage
support our Privacy Shield commitments. The U.S. Federal Trade Commission has
regulatory enforcement authority over our processing of personal information
received or transferred pursuant to Privacy Shield. We commit to cooperate and
comply with the advice of the regulatory authorities to whom you may raise a
concern about our processing of personal information about you pursuant to
Privacy Shield, including to the panel established by the EU authorities and the
Swiss FDPIC. This is provided at no cost to you.

If you do not feel that we have resolved your complaint or concern
satisfactorily you can contact our U.S. based third-party dispute provider (free
or charge) at https://feedback-form.truste.com/watchdog/request. Under certain
conditions, more fully described on the Privacy Shield website, you may invoke
binding arbitration when other dispute resolution procedures have been
exhausted.





INTERNATIONAL PRIVACY VERIFICATION

Whilst the Court of Justice of the European Union (CJEU) and the Swiss Federal
Data Protection and Information Commissioner (FDPIC) ruled the EU-U.S. and
Swiss-U.S. Privacy Shield Frameworks invalid in the summer of 2020, we remain
committed to the Privacy Shield Principles.  In recognition of our continued
commitment, in October 2020 we self-certified with the International Privacy
Verification programme (IPV). The IPV’s assessment criteria are aligned with
those of the Privacy Shield and therefore by certifying with the IPV we are able
to continue to demonstrate our compliance with the core Privacy Shield
Principles in relation to the protection of personal data transferred outside of
the UK and EU.

If you do not feel that we have resolved your complaint or concern
satisfactorily you can contact our U.S based third-party dispute provider (free
or charge) at https://feedback-form.truste.com/watchdog/request.




COOKIES

To find out more about cookies and how we use them,
see www.egress.com/legal/cookies. If you live in California, we need to let you
know that some web browsers may transmit “do-not-track” signals to the websites
and online services you communicate with. Whilst there is no industry standard
that governs what, if anything, we should do if we receive such a signal, our
website will not set cookies if you have your browser set to ‘Do not track’


CHANGES TO THIS POLICY

We can change this policy from time to time. You should check the website
periodically to make sure that you have read our most recent policy. When we do
make changes, we will change the date at the top of this document.


ABOUT US AND APPLICABLE LAW

We are the Egress Software Technologies Group. You can find out more details
about us at www.egress.com/about and you can contact us at info@egress.com. When
contacting us we strongly recommend you don’t email us confidential or personal
information. If you do, it is at your own risk although the terms of this policy
will apply to our use of that information.

Where you are resident

Who we are

Governing law

Courts with exclusive jurisdiction

Special Terms

United States

Egress Software Technologies, Inc., a Massachusetts corporation.

Office: Suite 2, Level 3, 268 Summer Street, Boston, MA 02110, United States

State of Delaware (without regard to its conflict of law principles).

State or federal courts in and for Boston, Massachusetts

Where applicable, each of us hereby waives its respective rights to a jury trial
of any claim or cause of action relating to or arising out of this policy. This
waiver is intended to encompass all disputes that may be filed in any court and
that relate to the subject matter of this policy (including contract, tort,
breach of duty and all other common law and statutory claims).

Canada

Egress Software Technologies Inc., an Ontario corporation

Office: Suite A304, 11685 Yonge Street, Richmond Hill, L4E 0K7, Canada

Province of Ontario

Province of Ontario

N/A

European Union or European Economic Area

Egress Software Technologies Limited.

A Foreign Entity registered on the Dutch Chamber of Commerce (number 74110462)

Office: Oval Tower, De Entrée 99-19, Amsterdam, 1101 HE, The Netherlands

Dutch Law

NCC District Court and NCC Court of Appeal Chamber

All proceedings will be in English.  In the event that the NCC District Court
and/or the NCC Court of Appeal Chamber are incompetent for any reason, the
Courts of Amsterdam, The Netherlands shall have exclusive jurisdiction.

Rest of the World

Egress Software Technologies Limited.

Registered in England and Wales (number 06393598).

Registered office: 12th Floor, The White Collar Factory, 1 Old Street Yard,
London, EC1Y 8AF, United Kingdom.

VAT number: 921 4606 46.

England and Wales (except if you're a consumer resident of Northern Ireland or
Scotland when you may bring proceedings there)

Courts of England and Wales (except if you're a consumer resident of Northern
Ireland or Scotland and have brought proceedings there when the Northern Irish
or Scottish Courts will have jurisdiction).

N/A

Our Sites are provided by Egress Software Technologies Limited, registered in
England and Wales (number 06393598) for and on behalf of itself and the other
members of the Egress Software Technologies Group.


EU REPRESENTATIVE

Egress Software Technologies Limited (a foreign company registered on the Dutch
Chamber of Commerce) further identified in the section above is our EU
representative.


GLOSSARY

Legitimate Interest means our interest in conducting and managing our business
to enable us to give you the best service and 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).

Performance of Contract means processing your personal information where
necessary for the performance of a contract that we have with you, or to take
steps 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.

Here are other specific privacy disclosures:

Platform Privacy Policy: www.egress.com/legal/privacy-policy

Visitor Privacy: www.egress.com/legal/visitor-privacy

Recruitment Privacy: www.egress.com/legal/recruitment-privacy

Event Privacy: www.egress.com/legal/event-privacy


VIEW LEGAL HUB

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Products
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