We are Protean Software America, LLC, a company organized in Wisconsin with its primary place of business at 635 3rd Street, Beloit, Wisconsin 53511(“we”/ “our” / “us”). We, along with our parent company, Protean Software Ltd., based in the United Kingdom, are committed to ensuring that your privacy is protected. In order to best protect the personal data of Website users, Protean Software America, LLC and Protean Software Ltd. have decided to comply with the EU-U.S. Privacy Shield Framework (“Privacy Shield Framework”). The Privacy Shield is a data protection framework designed by the U.S. Department of Commerce, the European Commission and Swiss Administration to provide European and United States companies with a mechanism to comply with data protection requirements when transferring personal data from the European Union (“EU”), Switzerland and the United States in support of transatlantic commerce. The following link will take you to a list of all companies that participate in the Privacy Shield: https://www.privacyshield.gov/list. We shall maintain a Privacy Shield policy (the “Privacy Shield Policy”) in order to comply with the seven Privacy Shield Principles (the “Principles”). Below are the seven Principles we agree to comply with.
I. Notice. We shall notify you about our data practices regarding personal data received by us in the U.S. from EU member countries and Switzerland in reliance on the Privacy Shield Framework, including types of personal data and information we collect about you, the purposes for which we collect and use such personal data, the types of third parties to which we disclose such personal data and the purposes for which we do so, your rights to access your personal data, the choices and means that we offer for limiting our use and disclosure of such personal data, how our obligations under the Privacy Shield Framework are enforced, and how you can contact us with any inquiries or complaints.
For the purposes of this Privacy Shield Policy, “personal data” or “personal information” shall mean any of your information that can be used to identify you either on its own or in combination with other readily available data. “Sensitive personal data” shall mean personal data regarding your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, criminal history, physical or mental health, or sexual life
II. Choice. If personal data covered by this Privacy Shield Policy is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, we will provide you with an opportunity to choose whether to have your personal data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to: Protean Software Ltd, 1130-1140 Elliot Court, Herald Avenue, Coventry Business Park, Coventry CV5 6UB. United Kingdom.
If sensitive personal data covered by this Privacy Shield Policy is to be used for a new purpose that is different from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a third party, we will obtain your explicit consent prior to such use or disclosure.
III. Accountability for Onward Transfer. In the event we transfer personal data covered by this Privacy Shield Policy to a third party acting as a controller, we will do so consistent with any notice provided to you and any consent you have given, and only if the third party has given us contractual assurances that it will (i) process the personal data for limited and specified purposes consistent with any consent provided by you, (ii) provide at least the same level of protection as is required by the Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the personal data or take other reasonable and appropriate steps to remediate if it makes such a determination. If we have knowledge that a third party acting as a controller is processing personal data covered by this Privacy Shield Policy in a way that is contrary to the Principles, we will take reasonable steps to prevent or stop such processing.
With respect to our agents, we will transfer only the personal data covered by this Privacy Shield Policy needed for an agent to deliver to us the requested product or service. Furthermore, we will (i) permit the agent to process such personal data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal data transferred in a manner consistent with our obligations under the Principles; and (iv) require the agent to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.
We remain liable under the Principles if an agent processes personal data covered by this Privacy Shield Policy in a manner inconsistent with the Principles, except where we are not responsible for the event giving rise to the damage.
IV. Security. We take reasonable and appropriate measures to protect personal data covered by this Privacy Shield Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the personal data.
V. Data Integrity and Purpose Limitation. We collect and process personal information only to the extent that it is compatible with the purposes for which it was collected or subsequently authorized by you. We do not retain personal information after it no longer serves the purposes for which it was collected or subsequently authorized. We take reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use.
VI. Access. You have the right to access your personal data and to correct, amend, or delete such personal data if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to your privacy, or where the rights of persons other than you would be violated). Requests for access, correction,amendment, or deletion should be sent to: Protean Software Ltd, 1130-1140 Elliot Court, Herald Avenue, Coventry Business Park, Coventry CV5 6UB. United Kingdom.
VII. Recourse, Enforcement and Liability. Our participation in the Privacy Shield Framework is subject to investigation and enforcement by the Federal Trade Commission. In compliance with the Privacy Shield Principles, Protean Software commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Protean Software at:
Protean Software has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU. If you have inquiries or complaints regarding this Privacy Shield Policy you should first contact us at: Protean Software Ltd, 1130-1140 Elliot Court, Herald Avenue, Coventry Business Park, Coventry CV5 6UB. United Kingdom.
In the event we are unable to resolve your concern, you may contact Jams, (https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim) which provides an independent third-party dispute resolution body based in the United States, and they will investigate and assist you free of charge. Under certain conditions detailed in the Privacy Shield, you may be able to invoke binding arbitration before the Privacy Shield Panel to be created by the
U.S. Department of Commerce and the European Commission.
We agree to periodically review and verify our compliance with the Principles, and to remedy any issues arising out of failure to comply with the Principles. We acknowledge that our failure to provide an annual self-certification to the U.S. Department of Commerce will result in our removal from the Department’s list of Privacy Shield participants,
Our Data Security Manager can be contacted using the following address DSM@proteansoftware.co.uk or alternatively writing to our principal address set out above and marking it for the attention of the Data Security Manager.
1. What information do we hold and how will we use it?
1.1 We may collect and process the following data about you:
We will retain this information for 2 years.
3. Use made of the information
3.2.4 to better understand how people interact with our websites;
4. Third Party Sites
5. How safe is your information?
5.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
6. Disclosure of your information
7. Your rights in respect of your data
7.1.1 Access to your information
You can ask us to confirm that we process your personal data and provide access to and copies of the information we hold about you by contacting us at Protean Software Ltd, 1130-1140 Elliot Court, Herald Avenue, Coventry Business Park, Coventry CV5 6UB. United Kingdom. We will process your request to access your information and provide this information to you free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge a reasonable fee if you request more than one copy of the same information.
We will provide the information you request as soon as possible and in any event within one month of receiving your request, unless there are extenuating circumstances. If we need more information to comply with your request, we will let you know.
• where we have collected your personal data on the grounds of consent and you withdraw that consent;
• where you object to the processing and we do not have any overriding legitimate interests to continuing processing the data;
• where the personal data has to be deleted to comply with a legal obligation; and
• where the personal data we process relates to the offer of online services to a child.
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we will let you know.
To request that your information is deleted, please contact us at Protean Software Ltd, 1130-1140 Elliot Court, Herald Avenue, Coventry Business Park, Coventry CV5 6UB. United Kingdom.
if you believe the personal data we hold is not accurate – we will cease processing it until we can verify its accuracy;
if you have objected to us processing the data (see below) – we will cease processing it until we have determined whether our legitimate interests override your objection;
if the processing is unlawful; or
if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
You are entitled to object to us processing your personal data:
• if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
• for direct marketing purposes (including profiling); and/or
• for the purposes of scientific or historical research and statistics.
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defense of a legal claim.
If you wish to restrict or object to the processing of your information, please contact us at Protean Software Ltd, 1130-1140 Elliot Court, Herald Avenue, Coventry Business Park, Coventry CV5 6UB. United Kingdom.
7.1.5 Data Portability
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies:
We will respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we will let you know.
7.4 Changes to Policy
We may update this policy from time to time. Any material changes will be posted to this
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