Privacy Policy

Testathon Privacy & Personal Data Protection Policy

updated July 6th 2020

At Testathon we believe in the importance of protecting your information and ensuring you have appropriate control over it, we’ve summarized the key points from within our Testahon Privacy & Personal Data Policy (“Policy”, “Privacy Policy”) – but of course we suggest reading it in full.

Only those within our organization with the appropriate access level are able to view your information & we restrict access on our end. We could send your information to our Clients, but only those you’re working with, and to the Testahon, you participated. We limit it to the purpose of the processing, and we secure it according to applicable law, regulations, and best practices. If Privacy Policy does not say otherwise, the vocabulary used in Privacy Policy should be understood as GDPR or other common law regulations say.

If you’d like to unsubscribe, access, amend or delete any information, please contact [email protected] 

If at any time you are concerned or have questions about how we might be handling your data, please reach out to our Data Protection Officer at [email protected]

If you do not accept and agree with our Privacy Policy, then you must not access or use Testahon or our services.

TABLE OF CONTENTS 

  • General

SPA Worldwide LTD (Company Number: 07606704) trading as Global App Testing (“GAT”, “We”, “Us” and “Our”) remains fully committed to the protection of your  privacy at all times. The information contained in Privacy Policy has been published to inform you of the way in which any Personal Data (as defined below) you provide us with or we collect from you will be used. Please read this information carefully in order to fully understand how we treat such Personal Data.Please read Privacy Policy in conjunction with our terms and conditions assigned to a given type of products and services. When you access or use GAT, you agree to our Privacy Policy, and you consent to our collection, storage, use, and disclosure of your Personal Data for the purpose of making GAT and/or the Service available to you, in accordance with Privacy Policy. Any capitalized terms not defined in Privacy Policy shall have the same meanings given to them in terms and conditions.

We may host events that include in-person meetings. If you register for a Testahon event we will collect your first and last name, email address, business or home address, information about the type of business you work for, which we will use to provide you with information and services associated with the event.

We will also use Cookies and tracking technologies to improve user experience with our websites.

We will collect, store, use and disclose Personal Data (Personal Information) in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, UK Data Protection Act 2018, The California Consumer Privacy Act (“CCPA”) as amended or superseded from time to time, and any national implementing legislation (“Data Protection Laws”).

For the purpose of Data Protection Laws, in relation to any Personal Data you or any Users submit to our platform, you will be the data controller, and we will be a data processor of such Personal Data.

  • Privacy principles

We adhere to the principles relating to the processing of Privacy & Personal Data.

  • Lawfulness, fairness and transparency

We collect, process, and share Personal Data fairly and lawfully and for specified purposes. The law restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent processing, but ensure that we process Personal Data fairly and without adversely affecting the Data Subject.

We provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. 

We provide the Data Subject with all the information required by the law, including the identity of the Data Controller and Data Protection Officer, how and why we will use, process, disclose, protect and retain that Personal Data.

We check that the Personal Data was collected by the third party in accordance with the law and on the basis that contemplates our proposed processing of that Personal Data.

  • Purpose limitation

We collect Personal Data only for specified, explicit and legitimate purposes. 

We do not use Personal Data for new, different, or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes, and they have consented where necessary.

  • Data minimization

We collect Personal Data only for specified, explicit, and legitimate purposes. We do not further process in any manner incompatible with those purposes.

We do not use Personal Data for new, different, or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes, and they have Consented where necessary.

  • Accuracy

We take all reasonable steps to ensure that Personal Data is not incorrect or misleading as to any matter of fact accurate and, where necessary, kept up to date. We correct or delete it without delay when inaccurate.

  • Storage limitation

We store Personal Data only for specified, explicit, and legitimate purposes. They’re not further processed in any manner incompatible with those purposes.

  • Integrity and confidentiality (security)

We secure Personal Data by appropriate technical and organizational methods or measures against unauthorized or unlawful processing and accidental loss, alteration, destruction, or damage.

  • Accountability

We implement appropriate technical and organizational methods or measures in an effective manner to ensure compliance with data protection principles, according to commonly accepted standards, laws, or internal regulations.

We are able to demonstrate compliance with the data protection principles. We recognize new laws and regulations and adapt our activities to changes in the context or broad -range framework or business environment.

We have adequate resources and controls in place to ensure and to document the law compliance including:

  • appoint a suitably qualified Data Protection Officer accountable for data privacy;
  • implement Privacy by Design, Privacy by Default and complete data protection risk assessment as part of Data Protection Impact Assessment (DPIA) where processing presents a high risk to rights and freedoms of Data Subjects;
  • integrating data protection into internal Information Security & Privacy Management System and documents;
  • regularly train our personnel on the Privacy and Personal Data;
  • periodically test the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.

We keep and maintain accurate records reflecting our processing, including records of Data Subjects’ Consent and procedures for obtaining Consent. These records include, at a minimum, contact details of the Data Controller and the Data Protection Officer, descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data’s retention period and a description of the security measures in place.

We ensure that all personnel have undergone adequate training to enable them to comply with data privacy laws. We regularly test our systems and processes to assess compliance with all of the regulations.

We do not share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place. We share the Personal Data internally if the recipient has a job-related need to know the information.

  • Information Collection

  • Services

“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We may obtain and use the following Personal Data and Sensitive Data about you and anyone you chose to add to our platform:

  • Your personal details e.g. Name, Gender, Language, Email address, Facebook and Linkedin Profiles, etc ……. 
  • Any correspondence we have with you  should you  contact us.
  • Data you  provide when you fill out forms on our Website or at one of our events, including but not limited to data you provide when you register to become a user of the Service.
  • Data and information you  submit or upload to Testathon or the Service or during the event, including employee data (which may include, among other things, apps, beta versions of your apps, user information, etc).
  • All data on the testing process and test case execution (e.g. entire test session, test cases, mouse movement, keyboard clicks, how to navigate on mobile devices, etc.).
  • Details of transactions made by you through the Website and or during the event.
  • Responses to optional research surveys we ask you or Users to complete.
  • Details of your ’ visits to our Website, which includes without limitation location and traffic data, weblogs, resources you access and other communication data.

We do not intentionally collect data which is, by its nature, particularly sensitive (e.g., genetic data, biometric data, data revealing racial or ethnic origin, political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, criminal background or trade union membership). All responsibility for providing data as above does not belong to GAT. Providing such data by our partners and other third parties or their processing in our services or infrastructure is considered unintentional, and we exclude all legal liability.

We also exclude all legal liability in case of unauthorized access or accidental loss, damage, corruption, or disclosure of your Personal Data or Sensitive Personal Data that was provided by you directly to our Partners or Clients.

The Customer may need additional Personal Data or Sensitive Personal Data to process the order. In such a situation, it is the Customer’s responsibility to obtain consent for such processing from you.

Regardless of the legal or factual relationship between two independent entities, Tester Work disclaims its liability for any non-compliance of standards, law, or GDPR resulting from a violation by independent entities. Tester Work reserves that it is not a participant in the relationship regarding the consent to the processing of sensitive data by either party. Nor shall it be liable for negligence, disclosures, or infringements even if they were caused by unintentional negligence in implementing Tester Work infrastructure security mechanisms, enabling the provision of data processing services. In this regard, you must carefully read our Policy, understand it, accept it, and follow the rules.

  • Website

Cookies and IP Addresses

We may obtain information about your  device, which includes your  public IP address, browser type, and operating system where available. This accumulation of data is used to assist system administration.

We may also collect information regarding your ‘ browsing activity and interests through the use of a cookie file. This cookie file is stored on the hard drive of your ‘ device and contains information that is transferred to your ‘ computer’s hard drive. We use the collection of this data to help us improve the experience of users on our Website and Service, and to deliver a more personalized service with more relevant content. The collection of this data allows us to:

  • store data indicative of your ‘ preferences, allowing us to adjust our Website to appeal to your individual interests;
  • estimate the size and usage patterns of our audience;
  • record the details of any transactions carried out by you through our Website;
  • identify you  upon your/their return to our Website; and/or
  • increase the speed of your ‘ searches.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Website and Service. They include, for example, cookies that enable you  to log into secure areas of our Website or Service.
  • Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Website and Service when they are using it. This helps us to improve the way our Website and Service works.
  • Functionality cookies. These are used to recognize you  when you/they return to our Website. This enables us to personalize our content for you , greet you  by name and remember your/their preferences.
  • Targeting cookies. These cookies record your  visit to our Website, the pages you  have visited and the links you  have followed. We will use this information to make our Website and the advertising displayed on it (if any) more relevant to your  interests. We may also share this information with third parties for this purpose.

You can find more information about some of the individual cookies we use and the purposes for which we use them below. Example of cookies used by the Service:

  • Tool Cookies Purposes
  • We would like to inform you that any action using external services excludes GAT’s liability for the violations and rights described in this Policy.

We use the services of many providers of data analysis solutions, below we indicate the most important ones. 

Social Media And Advertising Cookies

e.g. Facebook / LinkedIn / Twitter

We use Facebook and LinkedIn’s 3rd-party audience data such as age, gender, and interests to better understanding the behavior of our customers and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. For example, you may see certain ads on this Website or other websites because we contract with Facebook and other similar companies to target our ads based on information they or we have collected, including information that was collected through automated means (such as cookies and web beacons). These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.

Google Analytics / AdWords / Security

We use Google Analytics’ / Adwords’ 3rd-party audience data such as age, gender, and interests to better understanding the behavior of our customers and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. For example, you may see certain ads on this Website or other websites because we contract with Google and other similar companies to target our ads based on information they or we have collected, including information that was collected through automated means (such as cookies and web beacons). These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.

You may opt-out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/ 

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You  remain entitled to refuse cookies by adjusting your browser settings accordingly. Doing so, however, may restrict your  access to certain areas within our Website or Service. Unless you  adjust your/their browser settings to refuse cookies, our system will issue cookies when you/they log on to our Website. 

We use Google security service reCAPTCHA that protects our Website from spam and abuse. reCAPTCHA uses an advanced risk analysis engine and adaptive challenges to keep automated software from engaging in abusive activities on our site. This Google security service is used under Google privacy policy. You could read it here: https://policies.google.com/privacy?hl=en

  • Children

We care about the safety and privacy of children online. Our Website and services are not designed or directed at children. We do not intentionally collect any personal information from persons under the age of 16 years of age. If we become aware that we have inadvertently received personal information from a user under the age of 16, we will delete the information from our records according to the law (e.g., GDPR, CCPA, or Children’s Online Privacy Protection Act of 1998 (“COPPA”). If any of the laws is more severe, we will comply with it.

  • Use of Information

  • Why we use information

The rules for the processing of Personal Data, protection of privacy and freedom for private persons are clear to us, known and communicated to all our employees. We use information for ethical and legitimate purposes, legal and responsible business conduct.

  • What purpose we use Privacy Information (regarding to CCPA) or Personal Data (regarding to GDPR)

The Personal Data we hold about you  may be used in any of the following ways:

  • To provide you with the Service, including administration and management of your account.
  • To enable Users to access certain aspects of Testathon and limited Client Data pertinent to themselves.
  • To provide you and Users with user support.
  • To moderate your account.
  • For research and analytics purposes (for example, to improve the quality of the Service).
  • To ensure security for you, our staff and other users of the Service.
  • To comply with applicable Laws, court orders, government and law enforcement agencies’ requests.
  • To provide you with online personalised services and targeted advertising.
  • To send you further information about our services for which we think you may have an interest. This information will be supplied only where you have given consent.
  • To send you further information about our services based on a request we have received from you.
  • To fulfil the obligations we have in relation to any contracts we have in place with you.
  • To provide you with notification about any changes to the Service.

You agree to the above processing. We will never supply your ‘ Personal Data to third parties unless under the conditions stated beneath this section of our Privacy Policy. Notwithstanding the foregoing, you acknowledge and agree that we may aggregate and anonymize you , Personal Data, and use and share such aggregated and anonymized Personal Data with third parties for statistical purposes and for the purpose of data analytics, product development, and/or Service improvement.

We may also use your Personal Data to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use Personal Data for these purposes when it is necessary to protect, exercise, or defend our legal rights, or when we are required to do so by applicable law.

  • Information Storing

The Personal Data we obtain from you may be moved to and stored at a destination within the European Economic Area (“EEA”) and according to point 13 of Privacy Policy could be processed outside EEA depending on the purpose of processing.

Staff members operating within the EEA who work for or on behalf of us may process this information. 

Without limiting the foregoing, you agree that Personal Data we obtain from you may be processed by our service providers based in countries outside of the EEA. Such countries may not have laws offering the same level of protection for Personal Data as those inside the EEA.

We store the Personal Data you provide us with on our secure servers. The Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be moved to and stored at a destination within the European Economic Area (“EEA”) and according to point 14 of Privacy Policy could be processed outside EEA depending on the purpose of processing.

Staff members operating within the EEA who work for or on behalf of us may process this information. Such staff members may, among other things, be involved in the processing of payment details, the provision of support services, and the delivery of your and your Users’ request(s) for us to provide the Service.

Without limiting the foregoing, you agree that Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be processed by our service providers based in countries outside of the EEA for the purposes of providing you with the Service. Such countries may not have laws offering the same level of protection for Personal Data as those inside the EEA.

We store the Personal Data you  provide us with on our secure servers. In the event of us giving you  (or you/they choosing) a password that grants you/them access to specific areas within our Website or Service, it remains your/their responsibility to maintain the confidentiality of this password. This includes the obligation to refrain from sharing your/their password with other parties. As the transmission of data via the Internet cannot be assumed completely secure, we cannot guarantee the security of any of your ‘ data transmitted to our Website or Service; you are therefore responsible for any risk associated with such transmission. We will however at all times take all reasonable steps to ensure the transmission of your  data is executed as securely as possible, and upon receipt of your/their data, we will continue at all times to enforce strict security procedures and features in an attempt to prevent any unauthorized access. 

  • Data Retention

We process your Personal Data for the least amount of time necessary to our business and service needs, contractual requirements, in accordance with our data retention policies and applicable law. We do not collect more Personal Data than is necessary to fulfill our obligations to you or at law or for purposes stated in Privacy Policy.

Your Personal Data will not be kept in a form that allows you to be identified for any longer than is reasonably considered necessary by GAT for achieving the purposes for which it was collected or processed or as it is established in the applicable laws related to data retention periods or as permitted by applicable laws.

  • Information Sharing and Disclosure

Disclosure of your  Personal Data to third parties will only occur in any of the following events:

  • We sell or purchase any business or assets. In such a case, we may authorize the disclosure of your Personal Data to prospective sellers or buyers of such business or assets.
  • All or the substantial majority of our assets are sold to a third party. In such a case, your Personal Data may be one of the transferred assets.

We are required to disclose your ‘ Personal Data in order to fulfill any legal obligation, to enforce our terms and conditions, or to protect the property, rights, or safety of GAT, users of our services, or others. In such a case, information may be exchanged with third-party companies or organizations in order to prevent fraud or reduce credit risk.

You acknowledge and agree that we may also disclose Personal Data with: 

  • our service providers involved in the provision, distribution, delivery, and support of the Service; 
  • fraud prevention agencies; 
  • law enforcement agencies, regulators, courts and public authorities; and 
  • emergency services.

Our service providers have to follow our express instructions when processing the Personal Data you  provide and must have in place appropriate technical and organizational security measures to safeguard such Personal Data, and we do not allow them to use this information for their own commercial purposes.

If we do not process your Personal Data in accordance with our legitimate interest or based on a contractual obligation we have with you, we may share or disclose your Personal Data if you provide us with your affirmative consent.

  • Privacy Practices of Third Parties

We share the Personal Data we hold with third parties, according our internal Supplier Security Policy and supplier security and privacy risk assessment, such as our service providers if:

    • they have a need to know the information for the purposes of providing the contracted services;
    • sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject’s Consent has been obtained;
    • the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
    • the transfer complies with any applicable cross border transfer restrictions; 
    • the transfer complies with any law regulations or restrictions, especially for the authorized bodies or regulators.
  • a fully executed written contract that contains the law approved third party clauses has been obtained.
  • Your Rights

  • The right to be informed

You have a right to know about how we’re processing your Personal Data. Anything You should know is contained in the Privacy Policy. You may also email us at [email protected] to request additional information about how we’re processing your Personal Data.  

  • The right of access

You may email us at [email protected] to request a copy of the Personal Data we currently contain.

  • The right to rectification

You can correct what Personal Data We currently contain by emailing us at [email protected] to request that we correct or rectify any Personal Data that you have provided to us.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.  

  • The right to erasure

If you should wish to cease use of our services and have your Personal Data deleted, then you may submit a request by emailing us at [email protected] Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your Personal Data has been deleted.  Where applicable, we will ensure such changes are shared with trusted third parties.  

  • The right to restrict processing

When applicable, you may restrict the processing of your Personal Data by submitting a request via email to [email protected] In your email, please explain how you wish us to restrict the processing of your Personal Data.  When such restrictions are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Privacy Policy, to include withdrawing your consent to the processing of your Personal Data. Where applicable, we will ensure such changes are shared with trusted third parties.

  • The right to data portability

Upon request and when possible, we can provide you with copies of your Personal Data.  You may submit a request via email to [email protected]  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Privacy Policy, to include withdrawing your consent.  Where applicable, we will ensure such changes are shared with any trusted third parties.

  • The right to object

When applicable, you have the right to object to the processing of your Personal Data by submitting a request via email to [email protected] When such objections are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Privacy Policy, to include withdrawing your consent to the processing of your Personal Data. Where applicable, we will ensure such changes are shared with trusted third parties. 

  • The right to consent

At any time, you may withdraw your consent to our processing of your Personal Data through our Websites by notifying us via email at [email protected]  Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your Personal Data.  Where applicable, we will ensure such changes are shared with trusted third parties.

  • Rights in relation to automated decision making and profiling

Profiling is any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements. Profiling and automated decision-making are used in an increasing number of sectors, both private and public. Profiling and automated decision-making can pose significant risks for individuals’ rights and freedoms, which require appropriate safeguards. Profiling and automated individual decision-making are also covered by Directive (EU) 2016/680 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data by competent authorities for the purposes of the prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties, and on the free movement of such data. GAT does not currently use profiling mechanisms. GAT is not responsible for profiling data obtained from GAT into a legal manner and consent to Privacy Policy. 

We do not use your Personal Data to automated decision making and profiling in accordance with GDPR Article 22 (automated individual decision-making, including profiling, with legal or similarly significant effects).

  • Exercising my right

You can exercise any of your rights by contacting via email to [email protected]

We may need to request specific information from you to reasonably confirm your identity and verify you are the Person Data belong to. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request and to exercise your rights.

  • Fees

You will not have to pay a fee to access your Personal Data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

  • Accountability and governance

  • Contracts

Whenever we use a processor, there must be a written contract in place. If a processor uses another organization (i.e., a sub-processor) to assist in its processing of Personal Data for a controller, it needs to have a written contract in place with that sub-processor.

What we set up in the contract:

  • the subject matter of the processing;
  • the duration of the processing;
  • the nature and purpose of the processing;
  • the type of Personal Data involved;
  • the categories of the data subject;
  • the controller’s obligations and rights;
  • the privacy & security requirements;
  • the right to audit (if applicable).
  • Documentation

What is our documentation of processing activities:

  • we document all the applicable information under Article 30(1) of the GDPR;
  • we record all the applicable information under Article 30(2) of the GDPR.

If we process special category we document:

  • the condition for processing we rely on in the Data Protection Act 2018;
  • the lawful basis for our processing; 
  • whether we retain and erase the Personal Data in accordance with our internal documentation.

When preparing to document our processing activities we:

  • do information audits to find out what Personal Data our organization holds;
  • distribute questionnaires and talk to staff across the organization to get a complete picture of our processing activities; 
  • review our policies, procedures, contracts, and agreements to address areas such as retention, security, and data sharing.

As part of our record of processing activities we document, or link to documentation, on:

  • information required for privacy notices;
  • records of consent;
  • controller-processor contracts;
  • the location of Personal Data;
  • Information Security & Privacy Policies and Procedures;
  • Information & Privacy Risk Assessment;
  • Data Protection Impact Assessment; 
  • privacy & information security audit reports;
  • records of Personal Data breaches.

We document our processing activities in a granular way with important links between the different pieces of information.

We conduct regular reviews of the Personal Data we process and update our documentation accordingly.

We document our processing activities in writing and electronic form so we can add, remove, and amend information easily.

We share the results of processing your data, but we do not provide the above documents. 

  • Data protection and privacy “by design” and “by default”

We consider data protection issues as part of the design and implementation of systems, services, products, and business practices.

We make data protection an essential component of the core functionality of our processing systems and services.

We anticipate risks and privacy-invasive events before they occur and take steps to prevent harm to individuals.

We only process the Personal Data that we need for our purposes(s) and that we only use the data for those purposes.

We ensure that Personal Data is automatically protected in any our IT system, Service, product, and/or business practice so that individuals should not have to take any specific action to protect their privacy.

We provide contact information of those responsible for data protection both within our organization and to individuals.

We offer strong privacy defaults and controls.

We only use data processors that provide sufficient guarantees of their technical and organizational measures for data protection by design.

When we use other systems, services, or products in our processing activities, we make sure that we only use those whose designers and manufacturers take data protection issues into account.

  • Data protection risk & impact assessment

Our information security & privacy risk assessment and Data Protection Impact Assessments (DPIA) process is based on international standards and best practices.

  • Data protection officers

We have appointed a Data Protection Officer (DPO) based on their professional qualities and expert knowledge of data protection law and practices.

Our DPO reports directly to our highest level of management and is given the required independence to perform their tasks.

We involve our DPO, in a timely manner, in all issues relating to the protection of Personal Data.

We ensure that any other tasks or duties we assign our DPO do not result in a conflict of interest with their role as a DPO.

Our DPO is tasked with monitoring compliance with the GDPR and other data protection laws, our data protection policies, awareness-raising, training, and audits.

We take account of our DPO’s advice and the information they provide on our data protection obligations.

When carrying out a DPIA, we seek the advice of our DPO, who also monitors the process.

When performing their tasks, our DPO has due regard to the risk associated with processing operations and takes into account the nature, scope, context, and purposes of the processing.

Our DPO is easily accessible as a single point of contact for our employees, individuals, partners, contractors, third parties and the regulator. 

  • Security

We develop, implement and maintain an Information Security & Privacy Management System aligned with ISO 27001 standards and safeguards appropriate to our size, scope, and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Anonymization where applicable). We regularly evaluate and test the effectiveness of those safeguards to ensure the security of our processing of Personal Data. We exercise particular care in protecting Sensitive Personal Data from loss and unauthorized access, use, or disclosure.

We maintain data security by protecting the confidentiality, integrity, and availability of the Personal Data, defined as follows:

  • Confidentiality means that only people who have a need to know and are authorized to use the Personal Data can access it.
  • Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed.
  • Availability means that authorized users are able to access the Personal Data when they need it for authorized purposes.

We comply with and not attempt to circumvent the administrative, physical, and technical safeguards we implement and maintain in accordance with the law and relevant standards to protect Personal Data.

  • Incident response and breach reporting

We have put in place procedures to deal with any suspected security incident and Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

If you know or suspect that a security incident or Personal Data Breach has occurred immediately, contact via email to [email protected] You should preserve all evidence relating to the potential security incident and Personal Data Breach.

  • International Transfers of Personal Information

Information we collect from you will be processed in EEA and could be processed outside EEA, depending on the purpose of processing. Whenever Personal Data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. 

You could check how the EU determines if a non-EU country has an appropriate level of data protection by clicking the link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en .

You could check the commercial sector: EU-US Privacy Shield by clicking the link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_en .

To the extent permitted by applicable data protection laws, Personal Data may be transferred between various locations of GAT insofar as reasonably necessary for the purposes set out in this Privacy Policy and within the scope of legitimate interest of GAT. In any case, they are processed under the terms of Standard contractual clauses and Internal corporate rules adopted by all companies of GAT. 

If Personal Data is transferred outside the EU for doing business by GAT in other law jurisdictions, then EU law and law of the relevant jurisdiction apply jointly. If they are divergent, that stringent are used.

  • Links to Other Sites

We may, at times, provide links on our Website to third party websites, including without limitation those owned or managed by our partner networks, affiliates, or advertisers. These websites have separate privacy policies, and we, therefore, cannot accept any responsibility for the content. As such, choosing to follow these links is a choice you make at your own risk, and we advise that you check these websites’ individual privacy policies before submitting any Personal Data.

  • California Residents – The Privacy Rights (CCPA Privacy Notice)

This California Privacy Notice is part of the Privacy Policy. It is used when it is appropriate for GAT business. This section only applies to California residents. The rights discussed in this section do not extend to individuals who are not California residents. The California Consumer Privacy Act of 2018 (CCPA) requires that businesses disclose certain additional information about how it collects, uses, discloses, and sells the personal information of a California resident.

  • Right to Know/Right to Access General Collection and Use of Personal Information

If you are a California resident, you have the right to request that we disclose what information we have collected, used, disclosed, or sold over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you, based on your specific request:

  • The categories of personal information we collected about you over the past 12 months.
  • The specific pieces of personal information we have collected about you over the past 12 months.
  • The categories of sources from which the personal information is collected over the past 12 months.
  • The business or commercial purpose for collecting or selling that personal information over the past 12 months.
  • The categories of third parties with whom we shared your personal information over the past 12 months.

If we disclosed your personal information for a business purpose, the personal information categories that each category of recipients obtained. If we sell your personal information for a business purpose, the personal information categories that each category of recipients purchased.

  • Right to Request Deletion

If you are California resident, you have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete your personal information from our records, and direct our service providers to do the same, unless an exception applies.

  • Right to Opt-Out of Sale of Personal Information

If you are California resident and have 16 years old or more, you have the right to direct businesses that sell personal information to not sell your personal information.

  • Right to Opt-In to Sales of Personal Information for Minors Under 16

We do not intentionally process personal information children under 16 years old.

Under the CCPA, if you are California resident between 13 and 15 years old, you must affirmatively authorize the sale of your personal information or personal information. If the child is under the age of 13 years old, a parent or guardian must affirmatively authorize the sale of information. If you opt-in to personal information, sales may opt-out of future sales at any time.

  • Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

  • Financial incentives

We do not offer financial incentives permitted by the CCPA.

Under the CCPA, if you are California resident, we could offer you certain financial incentives permitted by the CCPA, or different prices, rates, levels, or quality of goods or services that are reasonably related to your personal information’s value to the business.

  • Exercising Your Right to Know

If you are a California resident, you can exercise the right to know/right to access information. You or your authorized agent may submit a verifiable request via email [email protected]

You may only make a verifiable request to know or request for access twice within a 12-month period. The verifiable request must include information that allows us to reasonably verify you are the person about whom we collect personal information or an authorized representative and describe your request in enough detail that we can properly understand, evaluate, and respond to it.

If we are able to verify your request, we will make our best effort to respond within forty-five (45) days of our receipt of your request. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We will not disclose information to you if we cannot verify your identity.

You will not have to pay a fee to access your Personal Data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

  • Exercising Your Right to Request Deletion

If you are a California resident, you can exercise the right to request deletion. You or your authorized agent may submit a verifiable request via email [email protected]

If we are able to verify your request, we will make our best effort to respond within forty-five (45) days of our receipt of your request. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. In our response, we will specify the manner in which we have deleted your personal information. We will not delete information if we cannot verify your identity.

  • Do Not Sell My Personal Information – Exercising Your Right to Opt-Out of Sale of Personal Information

For California residents to exercise the right to opt-out if we engage in selling your personal information, you or your authorized agent may submit a request via email [email protected]

We will act upon your request to opt-out within 30. (thirty) days of receiving the request. We will instruct the third parties to whom the information has been sold in the 30 days prior to your request not to further sell the information, and we will notify you when this instruction has been completed.

We will not act upon a request from authorized agents if the agent does not submit proof that the agent has been authorized by you to act on your behalf. We will not act upon a request if we believe it is fraudulent.

  • How We Verify California Residents’ Requests to Know/Requests for Access and Requests for Deletion

We will not respond to requests to know/requests for access or requests for deletion unless we can verify your identity to a reasonable degree of certainty. To verify your identity, when feasible, we will use information about you that we already have; however, we may need to request additional information, which we will use only for the purposes of verification. We may also use a third-party identity verification service. The information we need to verify your request will depend on the nature and scope of your request. Upon receipt of your request, we will notify you if we need additional information from you to verify your request.

  • Sale of Personal Information

We do not sell your personal information. 

  • Periodic review, changes to this Policy or procedures related to the Policy

We conduct periodic, not less than every 12 months Policy and Information Security & Privacy System Management and documentation reviews. Review is mandatory after changes the nature, scope, context, or purposes of the processing Personal Data. In all of aspect, this Policy, the reviewer must demonstrate independence, knowledge, and experiences according to Personal Data protection.

We are updating the Policy every 12 months and anytime if there are any material changes to the nature, scope, context, or purposes of the processing.

If at any time we make a change to this Policy, we will update this page to reflect such change. If we make material changes to how we treat your Personal Data, we will notify you by email. Through a notice on this page, however, we recommend you review this page periodically to ensure you remain happy with the latest version.

The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you.

  • Contact Us

We welcome any questions or comments in relation to this Privacy Policy, and advise you to send any such communication [email protected] or [email protected].

  • Brexit

We are monitoring the current developments with regards to UK Brexit and regulations that may arise.

Right now, the UK is still subject to the EU’s GDPR. The UK has its own version of the GDPR, the Data Protection Act 2018. There are no plans to repeal this law post-Brexit, but some changes are possible (link to actual https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/779335/Keeling_Schedule_for_GDPR.pdf  

and  https://www.legislation.gov.uk/uksi/2019/419/contents/made ).

You could check Brexit and data privacy impact in The Information Commissioner’s Office clicking the link: 

https://ico.org.uk/for-organisations/data-protection-and-brexit/