SLI is a leading provider of site search, navigation, and other e-commerce optimization services. This policy has been created in order to demonstrate our commitment to our Customers and other persons and organizations working with SLI. This policy describes our general practice and procedure for collecting, using and disclosing information about employees, agents, officers, workers and contractors of our customers, those of our commercial partners and visitors to our website (Individuals).
11.PRIVACY SHIELD FRAMEWORKS
(a) how SLI collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service,take part in a competition, contact us, schedule a demonstration or login to the website portal, register to become a partner or submit a partner referral form, fill in the ‘Get in Touch’ section of the website, register to download a document or view a video, or give us feedback;
(b) how SLI collects and processes data provided to us in the provision of our services to the persons or companies who engage SLI (our ‘Customers’); and
(c) how SLI collects and processes data relating to other persons or companies having a business relationship with SLI.
ATTN: Data Protection Officer
SLI U.S. Office: SLI New Zealand Office:
S.L.I. Systems, Inc. S.L.I. Systems, Inc.
101 Metro Drive, Suite 230 78 – 106 Manchester Street
San Jose, CA 95110 Christchurch, 8011
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
· Identity Data includes name, username or similar identifier, title.
· Customer Account Data includes preferences, survey responses and other feedback provided by you relating to your use of the SLI services.
· Contact Data includes email address and telephone numbers.
· Technical Data includes Internet Protocol (IP) address, browser information and preferences.
· Usage Data includes information about how you use our website and the features you interact with on our website, our products and our services.
· Marketing and Communications Data includes selected preferences in receiving marketing from us and our third parties and your communication preferences.
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.
· Direct interactions. You may give us your Identity, Customer Account, Contact, Marketing and Communications and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· apply for our products or services;
· subscribe to our service or publications;
· request marketing material to be sent to you;
· register to become a partner or submit a partner referral form;
· schedule/request a demonstration;
· login to our online portal;
· fill in the contact section of the website;
· enter a competition, promotion or survey;
· agree to participate in case studies to be published by SLI;
· give us some feedback; or
· as part of your interaction with SLI as you enter into a business relationship with SLI;
· Third parties or publicly available sources. We may receive personal data about Individuals from various third parties and public sources as set out below:
· Technical Data from the following parties:
· Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
· Identity and Contact Data from social networks.
· Identity and Contact Data from data brokers or aggregators.
· Identity and Contact Data from publicly availably sources, such as Companies House and the Electoral Register based inside the EU.
· Identity and Contact Data from providers of customer satisfaction services.
· Identity and Contact Data from service providers of data enrichment and deduplication services.
4. How we use your personal data
SLI may use and disclose personal data relating to Individuals for the purposes below.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
· We may aggregate your personal data with other aggregated data (so that it can no longer be associated with you) and process this data for research or statistical purposes.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
To register you as a new Customer
Necessary for our legitimate interests (to conclude our contract with our Customers and to provide access to our services under such contract)
To process and deliver your order for our services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and
(a) Necessary for our legitimate interests (to conclude our contract with our Customers)
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our contractual relationship with our Customers which will include:
(a) contacting Individual contacts at our Customers for account administration, support and
(b) responding to support queries raised by Individual users of our Customers
(c) Marketing and
Necessary for our legitimate interests (to ensure we comply with our contractual obligations to our Customers and respond to queries raised in connection with our services).
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) Marketing and
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to understand how Customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey/case study
(d) Marketing and
(a) Necessary for our legitimate interests (to understand how Customers use our products/services, to develop our relationship with our Customers and to grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand
(d) Marketing and
Necessary for our legitimate interests (to study how Customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, Customer
Necessary for our legitimate interests (to define types of Customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to deliver our products/services per contracts and develop and grow our business)
To manage our relationships with our business partners
(c) Marketing and Communications
Necessary for our legitimate interests (to conclude and/or maintain our relationship with business partners and third party suppliers)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Customer Account, Contact, Technical, and Usage 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 products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing. You may also receive marketing communications from us if you have consented to receiving such marketing communications from us.
We will get your express opt-in consent before we share your personal data with any company outside the SLI group of companies for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us. All marketing emails will contain an “unsubscribe” link at the bottom allowing you to opt-out of email communications from us. Additionally, you can unsubscribe here.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase, warranty registration, product/service experience or other transactions.
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.
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Other members of the SLI Group as set out in the Glossary.
- External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We share your personal data within the SLI group of companies. This will involve transferring your data outside the European Economic Area (EEA).
Many of our External Third Parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer personal data to them. We will not transfer any personal data to a third-party in the US without first ensuring, via written contract, that the third-party handles the data under the same level of protection as set forth in this policy.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. You can also read more about our enrollment in the Privacy Shield Frameworks with respect to data transfers from the EEA to the U.S. in Section 11 of this policy.
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.
SLI takes reasonable precautions to protect personal data relating to Individuals which is processed and collected by SLI. SLI follows generally accepted industry standard security measures to secure such personal data and protect it from unauthorized access or against loss, misuse or alteration by third parties. SLI maintains personal data behind a firewall.
Although we make good faith efforts to store personal data in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of personal data during its transmission or its storage on our systems.
Further, while we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information.
We do not warrant or represent that personal data will be protected against, loss, misuse, or alteration by third parties.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data can be requested from us by contacting us.
By law we have to keep basic information about our Customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being Customers for tax purposes.
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:this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This is commonly known as a “data subject access request”.
- Request correction of your personal data: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 can also 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.
- 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 your personal data:this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
- Request transfer of your personal data:we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. (Note: 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.You may also have the right to contact your local data protection authority to exercise your GDPR rights. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
Please note, where we process your information for statistical purposes, certain of the above rights will not be available to you. Please contact us for further information on which of the above rights will not apply to our processing of personal data for statistical purposes.
What we may need from you
Where we are not able to determine with any degree of certainty whether the information requested by you relates exclusively to you, our disclosure of such information to you may pose a privacy risk to a third party (for example, where a cookie is associated with a device used by more than one person), we will assess each request to exercise any of the rights listed above individually on its merits and will disclose the requested information where we are satisfied that such disclosure does not represent a privacy risk to any third party.
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 may refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Legitimate Interestmeans the interest of SLI 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 Contractmeans 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 or regulatory obligationmeans processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
- Service providers acting as processors based in the UK, USA, Australia, Japan and New Zealand who provide IT and system administration services.
- Service providers acting as processors based in the UK, USA, Australia, Japan and New Zealand whose services enable us to send marketing communications to our Customers, measure the effectiveness of marketing communications, send feedback requests and surveys to our Customers, to provide support services to our Customers, and to provide solutions which enable marketing services to SLI.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, who require reporting of processing activities in certain circumstances.
- Customers acting as controllers who require us to provide Customer Account data regarding use of our services by Individuals.
Other companies in the SLI Group, who may be based in the U.S., United Kingdom, New Zealand, Australia and/or Japan, providing IT and system administration services and undertaking leadership reporting from time to time.
Commitment to Privacy Shield Frameworks
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, S.L.I. Systems, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal data relating to you in the United States. Upon request and as may be required by the Privacy Shield Frameworks, we will provide you with access to the personal data that we hold about you. You may also request us to correct, amend, or delete the personal data we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove, view or modify data, we will respond within a reasonable timeframe. Where SLI is processing personal data on behalf of its Customers, SLI may refer a request to the relevant Customer and will support such Customer as needed in responding to the request.
Your right to access your personal data may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or when the rights of persons other than you would be violated by the provision of such access. If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.
We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. You may contact us at email@example.com SLI’s use or disclosure of your personal data.
S.L.I. Systems, Inc.’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, S.L.I. Systems, Inc. remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless S.L.I. Systems, Inc. proves that it is not responsible for the event giving rise to any damage.
Privacy Shield Dispute Resolution
In compliance with the Privacy Shield Principles, S.L.I. Systems, Inc. (U.S.) commits to resolve complaints about your privacy and our collection or use of your personal data transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact S.L.I. Systems, Inc.at: firstname.lastname@example.org
S.L.I. Systems, Inc.(U.S.)has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction