This document was last updated Nov 2022
1. GENERAL INFORMATION
1.1. “Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, SecurePalm (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of SecurePalm or any other person in respect of an individual.
1.3. As part of the search functionality, third parties may collect or receive information (including, without limitation, IP addresses and search terms) and use that information to provide measurement services, search results and other advertisements, including personalized and targeted search results and advertisements.
2. THE SOURCES OF THE INFORMATION WE COLLECT
3. THE TYPES OF PERSONAL DATA WE COLLECT
We may collect and receive a variety of information from you or about you or your devices from various sources, as described below. If you do not provide your Personal Data when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.
3.1. Information that you provide to SecurePalm. This includes Personal Data about you that you provide to us. The nature of the Services you are requesting or using will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
3.2. Information that we collect or generate about you. This includes (by way of non-exhaustive list):
3.4. Anonymized data. In addition to the categories of Personal Data described above, SecurePalm may also process further anonymized information or de-identified and aggregated with other data that is not processed by reference to a specific individual.
4. HOW WE USE YOUR INFORMATION
4.1. We may process your Personal Data for the following purposes:
4.2. When we process Personal Data we verify the existence of a lawful ground for such processing activity, including:
5. DISCLOSURE OF INFORMATION TO THIRD PARTIES
We may share or otherwise disclose the Personal Data we collect from you as described below or otherwise disclosed to you at the time of the collection.
6. INTERNATIONAL TRANSFERS OF PERSONAL DATA
You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA or the UK (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in paragraph 13 below.
6.3. China. For residents in the mainland of the People’s Republic of China (“Mainland China”), we may transfer, access or store your Personal Data outside of the Mainland China where we are satisfied that adequate levels of protection are in place to protect the integrity and security of your Personal Data or adequate security measures are adopted and in compliance with the applicable laws, such as contractual arrangements. Where required by applicable laws, we will put in place appropriate measures to ensure that all processing of your Personal Data outside of the Mainland China is safeguarded by the equivalent level of data protection in the Mainland China.
7. YOUR RIGHTS
7.1. Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.
7.2. Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
If you choose not to provide us with the Personal Data we collect, some features of our Services may not work as intended.
7.3. Your European Privacy Rights. If you are located in the EEA or the UK, you have additional rights described below.
8. HOW WE SAFEGUARD YOUR INFORMATION
8.1. We have extensive controls in place to maintain the security of our information and information systems. Files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorized employees.
8.2. As a condition of employment, SecurePalm employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need it to perform their roles. Unauthorized use or disclosure of confidential information by our employees is prohibited and may result in disciplinary measures.
8.3. SecurePalm requires its worldwide employees and contractors that have access to its internal systems to complete annual trainings on data protection and security. Such trainings are aimed to make sure that SecurePalm’s personnel understand and follow SecurePalm’s privacy policies and guidelines when handling Personal Data.
8.4. When you contact a SecurePalm representative, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.
9. THIRD PARTIES
10. HOW LONG WE KEEP YOUR PERSONAL DATA
We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period. When we process Personal Data for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrollment with our Services, the impact on our Services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.
11. CHILDREN’S PRIVACY
SecurePalm Tech (SecurePalm’s mother company) registered office may be contacted using the following contact information:
SecurePalm Tech Pvt Limited
600 White Oakrigde Road
Short Hills, New Jersey
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