Disguise's Privacy Policy

 

Date:  4th July 2018

 

Disguise Technologies Limited, including any affiliates and subsidiaries (“Disguise”, “we,” “us,” “our”) respect your privacy and is committed to protecting your personal data. This privacy policy will inform you how we look after your personal data if you are a customer, supplier or professional contact of us, when you use www.disguise.one and our affiliated websites, applications, and online services (collectively, our “Websites”) or otherwise provide us with such personal data. 

 

It is important that you read this Privacy Policy, together with any other privacy policy we may provide from time to time, so that you are fully aware of how and why we are using your data.

 

BY USING OUR WEBSITES AND/OR SERVICES OR OTHERWISE PROVIDING YOUR PERSONAL DATA TO US, YOU ARE ACCEPTING THE TERMS OF THIS PRIVACY POLICY AND OUR  AND YOU ARE CONSENTING TO OUR COLLECTION, USE, DISCLOSURE, AND PROTECTION OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

 

If you do not agree to the terms of this Privacy Policy, please do not use our Websites, purchase our services/goods or otherwise provide us with your personal data.  We may make changes to this Privacy Policy from time to time and the Privacy Policy will be located at https://www.disguise.one/en/privacy-policy/.  Your continued use of our Websites, purchase of our services/goods or provision of personal data following the updating of our Privacy Policy will mean you accept those changes.

 

This Privacy Policy does not apply to third-party websites, plug-ins and mobile applications that may link to the Websites or be linked to on the Websites.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We are not responsible for the actions or privacy practices of third-party websites and applications; please consult those websites and applications directly to understand their privacy practices.

 

INFORMATION ABOUT US

Disguise Technologies Limited (a company incorporated in England and Wales with company number 07937973) is the controller and responsible for your personal data. We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.

 

Contact details

Our full contact details are as follows:

Address:  Unit C&D, 127 Great Suffolk Street, London, United Kingdom, SE1 1PP

Telephone Number: +44 (0)20 7234 9840

Data Privacy Manager:  Nikita Bazalo

Email address: marketing@disguise.one

 

INFORMATION WE COLLECT ABOUT YOU

 

We collect, process, retain and transfer the following personal data:

 

Information You Give Us:  Whether you are a supplier or customer (including a prospective customer) we receive and store information you provide us (whether from the telephone, email or on our Websites or at any event such as a tradeshow) including your name, postal address, phone number, bank account, payment card details and email address and other related details required so that we can provide our goods and/or services.

 

Information We Automatically Collect:  We collect information about your use of our Websites, such as the purchases you make, the pages you view and other interactions you have.  Our Websites use “cookies” tagging and other tracking technologies to help enable you to shop on our Websites, and enable us to enhance or personalise your online browsing and service experience.  This information includes computer and connection information such as statistics on your page views, traffic to and from our Websites, referral URL, ad data, your IP address, and device identifiers. This information also may include your browsing history, transaction history, and your web log information.

 

Information From Social Media:  When you interact with us or our Websites on a social media platform, we may collect the personal data that you make available to us on that page, including your account ID or username and other information included in your posts.

 

Information From Other Sources:  We may collect information about you from third parties or collected offline, such as information collected by Disguise at events, or through our sales partners, or through sponsorship of events including but not limited to webinars, or through market research, or collected over the phone and add it to your account information.  This information may include, but is not limited to, demographic information that is publically available, additional contact information, group affiliations, and occupational information.

 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

HOW WE USE YOUR PERSONAL DATA

 

We use your personal data when the law allows us to and to help us personalise and continually improve your experience interacting with us, including fulfilling your orders and requests for information, analysing and compiling trends and statistics, and communicating with you.

 

Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • 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

 

More specifically, we have set out below, in a table format, a description of 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.

 

Purpose/Activity
Lawful basis for processing including basis of legitimate interest

To register you as a new customer or supplier

Performance of a contract with you

 

To verify your identity and to identify you when you contact us.

Performance of a contract with you

 

To process and deliver your order including:

(a) manage payments, fees and charges

(b) collect and recover money owed to us

(c) delivery products or services (including any training course orders) whether undertaken by us or by a third party, such as a sales partner

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To provide requested content, products and services to you (including free software trials and general enquiry forms based on our Websites)

Performance of a contract with you.

To manage warranty claims, servicing activities, and queries regarding our goods or services provided to you

(a)    Performance of a contract with you

(b)    Necessary for our legitimate interests (to provide aftercare services to you).

To manage our relationship with you which will include:

(a) Communicate with you about your account or transactions

(b) Notifying you about changes to our terms or privacy policy

(c) Asking you to leave a review or take a survey or feedback form (for example, as a result of our training)

(d) Send you information about features and enhancements on our Websites

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To send newsletters, offers and promotions for our products and services, third party products and services, or special events by e-mail, text, or another medium

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer newsletters, contests, sweepstakes, promotions, and surveys

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To serve you advertisements on selected, third party websites that make their advertising space available to us by using retargeting cookies

Necessary for our legitimate interests (to market and develop the growth of our business)

To administer and protect our business and our Websites (including but not limited to troubleshooting, data analysis, testing (including processing beta list of customers who assist with testing software developments, 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 the effectiveness of the advertising we serve to you

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 and perform statistical, demographic, and marketing analyses of users and purchasing patterns to improve our Websites, products/services, marketing, customer relationships and experiences

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 services that may be of interest to you.

(1)   Consent (where you have provided positive consent)

(2)   Necessary for our legitimate interests (to develop our products/services and grow our business)

To invite you to seminars or events, or send you information about features and enhancements to our Websites, or to tell you about developments at Disguise or in our industry more generally or marketing for services or goods in general.

(1)   Consent (where you have provided positive consent)

(2)   Necessary for our legitimate interests (to develop our products/services and grow our business)

To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal;

 

Necessary to comply with a legal obligation

 

We may use the information from one portion of the Websites on other portions of the Websites, and we may combine information gathered from multiple portions of the Websites into a single record.  We also may use or combine information that we collect offline or we collect or receive from third-party sources for many reasons, including to enhance, expand, and check the accuracy of our records. Additionally, information collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.

 

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.

In addition, we may process your personal data without your knowledge or consent, where this is required or permitted by law.

 

Marketing

We may use your personal 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 services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or the personal data has been lawfully transferred to us for such purpose and, in each case, you have not opted out of receiving that marketing on the basis that this within our legitimate interests to do so.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us using the details above at any time.

 

HOW WE SHARE YOUR INFORMATION WITH OTHERS

 

We share your personal data with third parties as described below.  In addition, we may share information that does not specifically and personally identify you, such as aggregate information, device identifiers or other unique identifiers to third parties.

Third-Party Service Providers:  We engage third-party service providers to perform functions on our behalf such as: hosting, marketing, social media integration, and analytics.  For example, we use third parties to process payments made to us and assist with product fulfillment and other operations.  These third parties may have access to your personal data when needed to perform their functions.  If we share information with these third parties that personally identifies you, such as your name, address, or phone number, we will require the third parties to maintain the confidentiality and security of your personal data, and they will be restricted from using, selling, or distributing such personally identifiable information in any way other than to provide the requested services to the Websites or as otherwise required or expressly permitted by law. 

Businesses in the supply chain: including suppliers, customers and any other person involved to enable us to perform our obligations or related matters pursuant to our business contracts.

Professional advisers: including lawyers, bankers, auditors and insurers who provide, for example, consultancy, banking, legal, insurance and accounting services.

Business Partners:  We may share information that personally identifies you with business partners, including our certified sales partners, who provide products and services that we think you may be interested in.

Sale, Assignment or Change of Control:  We may change our ownership or corporate organisation from time to time.  We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, investment (whether equity or debt) or financing transaction.  Under such circumstances, we will request the acquiring party to follow the practices described in this Privacy Policy with respect to previously collected information.  Nevertheless, we cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy.

Law Enforcement, Legal Process, and Emergency Situations:  We may also use or disclose your personal data if required to do so by law or on the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us; (b) protect and defend our rights, property, products or services, the Websites or our users, or (c) act to protect the personal safety of us and other people including but not limited to our customers, our suppliers, business partners, users of the Websites or the public.  For example, if you post content information on any of our Websites, we may disclose your information to a third party that alleges that you have infringed their intellectual property rights.  Similarly, if you allege that a third party website is infringing upon your intellectual property rights, we may disclose your information to that third party website.

 

INTERNATIONAL TRANSFERS

We may transfer your personal data to third parties providing services to us who are based outside of the European Economic Area (“EEA”). Some of these countries may not, in the opinion of the relevant EU and UK authorities, have adequate level of data protection and, therefore, allowing your data to be transferred to such countries may expose you to some level of risk that your data is not adequately protected.

This includes (but is not limited to) parties providing IT administration services and hosting services, and our sales partners who, we believe, will be able to best serve you in respect of the provision of our products and services.  We believe that in many situations, such as when we transfer contact details to our sales partners, that this is necessary for the performance of a contract and to ultimately provide you with a high level of services and goods.  Otherwise, if we cannot transfer such personal data in that way, then our sales partners will be, for example, unable to contact and/or deliver services to you.

Whenever we transfer your personal data outside of the EEA, we endeavour to ensure that the recipient promises to comply with the same data protection laws as we do.

By submitting your personal data to us, you are consenting to this type of international transfer, storing or processing. 

However, if you do not want your personal data to be transferred to or stored outside the EEA then please do not send us your personal data. By providing your information to us you agree and consent to us transferring to, and storing your information at, a destination outside the EEA.

 

DATA RETENTION

 

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.

For more details of our specific retention periods, please contact our Data Privacy Manager.

 

HOW TO ACCESS AND MODIFY YOUR INFORMATION

 

This version was last updated on 4th July 2018. We may update this Privacy Policy over time – please check this page https://www.disguise.one/en/privacy-policy/ regularly, or contact us, for the latest version.

 

Separately, if you have an online account with us, you can update your account information through your account.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

YOUR LEGAL RIGHTS

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are set out below.  If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager. 

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.

 

Complaint to the ICO

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.

 

Your legal rights

Your legal rights are as follows:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
  • 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 also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below).
  • 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.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain circumstances, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent at any time where we are relying on consent to process your personal data, although this may mean we are unable to provide certain benefits or assistance to you.

 

CHOICES ABOUT HOW YOUR INFORMATION IS USED AND SHARED

 

Further to the rights you have set out above, we will follow the option(s) you select when you are asked to register or fill in a form on our Websites regarding how your contact information is used and shared. 

 

While you cannot opt-out of receiving notifications and other communications regarding your account or your transactions, you can opt-out of receiving promotional and other marketing emails from us by: (1) using the “unsubscribe” feature in our marketing e-mails or (2) contacting the Data Privacy Manager on the contact details above.

 

COOKIES, TRACKING TECHNOLOGY, RETARGETING TECHNOLOGY AND INTEREST-BASED ADVERTISING

 

Like many websites, we use tracking technologies such as cookies (including, from time to time, retargeting technology for the purposes of tailoring our advertising to persons who we feel will benefit greatly from our products and services), web beacons, and similar technologies to record your preferences, and track the use of our Websites and exposure to our online advertisements.  We may also use these technologies to monitor traffic, improve the Websites, and make it easier to use and more relevant.  Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Websites may not work or may not work as designed.

 

Some content or applications on the Websites may be served by unaffiliated third parties.  We do not control these third parties’ tracking technologies or how they may be used.  As mentioned above, we are not responsible for the content or privacy practices on any website not operated by us to which our Websites link or that link to our Websites.

 

Your browser or device may include “Do Not Track” functionality.  Our information collection and disclosure practices, and the choices that we provide to visitors, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.

 

Online Tracking and Interest-Based Advertising Choices:  You also have choices to limit some tracking mechanisms that collect information when you use the Websites.  Many web browsers automatically accept cookies, but you can usually modify your browser’s setting to decline cookies if you prefer.  If you choose to decline cookies, certain features of our Websites, including the Websites themselves, may not function properly or remain accessible to you.  In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies.  Note that if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences. 

 

We use Google Analytics, a web analytics service provided by Google, Inc., on our Websites. Google Analytics uses cookies or other tracking technologies to help us analyse how users interact with and use the Websites, compile reports on the Websites’ activity, and provide other services related to Websites activity and usage.  The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website.  The Websites do not use Google Analytics to gather information that personally identifies you.  The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google click here.

 

HOW WE SECURE YOUR INFORMATION

 

Disguise uses a variety of managerial, technical, and physical measures to protect the integrity and security of your information. These measures may vary based on the sensitivity of your information. However, no security precautions or systems can be completely secure.  We cannot ensure or warrant the security of any information you transmit to Disguise, and you do so at your own risk.  We cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

 

You can help protect the privacy of your own information by using encryption and other techniques to prevent unauthorised interception of your personal data.  You are responsible for the security of your information that you transmit to us or view, download, or otherwise access when using unencrypted, public or otherwise unsecured networks.

 

OTHER IMPORTANT INFORMATION

 

Minors:  Our Websites are intended for users ages 13 and older only.  Accordingly, we will not knowingly collect or use any personal information from children that we know to be under the age of 13.  If we become aware of personal information in our database that was collected from a child under 13, we will delete such information.

 

Your California Privacy Rights:  If you are a California resident, California law permits you to request certain information regarding the disclosure of your personal information by us and our related companies to third parties for the third parties' direct marketing purposes.  To make such a request, please send your request, by mail or email, to:

disguise Systems Inc.

343 Grand Street

Brooklyn, NY 11211

Email:  info@disguise.one