Introduction
This SeeChange Privacy Statement (“Privacy Statement“) describes our privacy practices. Please read this Privacy Statement carefully to learn how we collect, use, share and otherwise process information relating to individuals (“Personal Data“), and to learn about your rights and choices regarding our processing of your Personal Data.
A reference to “SeeChange”, “we,” “us” or the “Company” is a reference to SeeChange Technologies Ltd.
Scope
SeeChange is the controller of your Personal Data as described in this Privacy Statement.
For the avoidance of doubt, this Privacy Statement does not apply to the extent we process Personal Data in the role of a processor on behalf of our customers, including where we offer to our customers various cloud products and services.
Types of Processing Activities
This Privacy Statement applies to the processing of Personal Data collected by us when you:
Personal Data We Collect
1. Directly from you
The Personal Data that we collect directly from you includes the following:
If you provide us with any Personal Data relating to other individuals, you must explain to those individuals that their Personal Data will be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or if you otherwise wish to exercise your rights relating to your Personal Data, please contact us by using the information set out in the “Contact Us” section below.
2. From other sources
We also collect information about you from other sources and combine this information with Personal Data provided by you. This helps us to update, expand and analyze our records, identify new customers and create more tailored advertising to provide services that may be of interest to you. In particular, we collect Personal Data from third party providers of business contact information, including professional contact details, employment-related information (such as job titles) and device / location-related information (such as IP addresses) for purposes of targeted advertising, delivering relevant email content, event promotion and profiling.
We obtain information through partners, vendors, suppliers and other third parties. These enterprises largely fall into the following categories: partners, hosts or vendors at events or trade shows, research partners and enterprises that deploy SeeChange technology or third-party offerings that include SeeChange technology. We might also obtain information through a partner as part of our business operations. This kind of data is used for work such as improving algorithms and data models, product testing and improvement, enhancing existing products and developing new capabilities and features.
Device and Usage Data
We use common information-gathering tools, such as cookies, web beacons and similar technologies, to automatically collect information that may contain Personal Data from your computer or mobile device as you navigate our websites, our services or interact with emails we have sent to you.
We gather certain information automatically in connection with the use of our website by individual users. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage.
In addition, we gather certain information automatically as part of your use of the cloud products and services. This information may include the information described in the preceding paragraph.
This device and usage data is primarily used for the purposes of identifying the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual (e.g., by means of an obvious identifier, such as a name) for security purposes or as required as part of our provision of the services to our customers (where we act as a processor). In any event, device and usage data will constitute your Personal Data.
Why and How We Use Your Information
We collect and process your Personal Data for the purposes and on the legal bases identified in the following:
Where we need to collect and process Personal Data by law, or under a contract we have entered or will enter into with you, and you fail to provide the required Personal Data when requested, we may be unable to perform our contract with you.
When and how can SeeChange share your Personal Data?
Sharing with third parties
We share information with the following third parties:
Sharing within SeeChange
We share your information within SeeChange in order to provide, maintain and develop our products and services. SeeChange employees will only access the information to the extent necessary to achieve the particular purpose(s) and perform their job.
We also share information that is not Personal Data, such as anonymised or aggregated information, for purposes such as analysis, identifying trends in the areas of our products and to help research and develop new SeeChange services.
Data Aggregation and Analytics
We collate your Personal Data which you provide to us or we collect and use it anonymously for analytics, benchmarking and to effectively monitor our website and improve your user experience.
How long do we retain your information for?
We retain Personal Data for the period necessary to:
Retention periods can vary significantly based on the type of information and how it is used and our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our SeeChange intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When Personal Data is removed from our systems, it will be deleted or destroyed using appropriate security protocols so that it cannot be reconstructed or read.
Your legal rights
If you are located in a European Union Member State and certain other countries, you have the following additional rights:
Access and / or have your information provided to you
You can request a copy of the Personal Data we are processing about you.
Change or correct
You can ask us to change, fix or update information about you (for example, if it is incomplete or inaccurate).
Deletion
You can ask us to delete Personal Data about you.
Restrictor limit use
You have the right to restrict our processing (i.e., stop any active processing) of your Personal Data (for example, if the information about you is inaccurate).
Portability
In certain circumstances, you have the right to obtain Personal Data we hold about you in a structured, electronic format, and to transmit such data to another data controller.
Object
You have the right to object to SeeChange using your Personal Data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). See below for information about how to unsubscribe to direct marketing.
Opt-out
You can withdraw your consent, including for marketing messages that you receive from us.
Please note that these rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority as described below.
International Transfer of Personal Data
Your Personal Data may be collected, transferred to and stored by us in the United States and by our affiliates and third parties disclosed above, that are based in other countries.
Therefore, your Personal Data may be processed outside your jurisdiction, and in countries that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area (EEA). We ensure that the recipient of your Personal Data offers an adequate level of protection, for instance by entering into the appropriate data processing agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR).
Children’s Privacy
We will not knowingly collect Personal Data from children under the age of 13 years.
Changes
We may modify this Privacy Statement at any time. If we make changes to this Privacy Statement, then we will post an updated version of this Privacy Statement on our website.
Contact Us
If you believe we have used your Personal Data in a way that is not consistent with this Privacy Statement or your choices, or if you have any questions or comments about this Privacy Statement, please contact us. Any request will be evaluated and completed in accordance with applicable data protection law, including verification of the requestor’s identity.
Last updated: September 6, 2021