Privacy Policy

This Privacy Policy is effective May 25 2018.

Welcome to the website of Centerity Systems Inc. and Centerity LTD. (“Centerity Systems” or “Centerity” “Website“). Your privacy is important to us. For that reason, we have adopted this Privacy Policy to explain our information gathering and use practices of Centerity Systems. Centerity Systems is committed to protecting the privacy of individuals who visit the Website and individuals who register to use our IT Industry Information Subscription Monitoring Software System services (“ Customer(s)“). This Privacy Policy describes our privacy practices in relation to the use of the Website and the services we offer (the “Services”).

Please note that we have adopted a Data Protection Addendum which applies when we process customers’ personal information within our Service. If you wish to receive a copy please email us at info-us@centerity.com

When We Collect Information

Personal Data That You Provide Through the Website. When visiting our Website, we may require you to provide us with personally identifiable information, or you may choose to give us personal information for many reasons, such as: contact information (when registering on our Website to obtain services or inquiring about becoming a supplier or business partner), education and work experience (when applying for a job), credit card details (to pay for services), facts about yourself, your business, profession and product preferences, subscribing to newsletters, by corresponding with us by phone, e-mail or otherwise using our contact details.

Business Contact and Customer Relationship Management. We collect and maintain information about our Customers, which may include company name, business contact name and title, phone number, email and other contact details. We may also collect billing address, financial account, credit card information, order details, subscription and license information, and usage details. In addition, we collect user credential and profile data (name, contact, authorized users) of Customer’s authorized users and account administrators.

Third Parties. We may also obtain personal data about Customers from third parties, such as LinkedIn and other publicly accessible sources.

Customer Data. As a provider of Services, we may receive, process or store certain information, including personal information, on behalf of our Customers. All such information (“Customer Data”) is owned and controlled by our Customers, who are the data controllers for such information with respect to EU data protection law or other applicable laws. Customer Data may include information from the end points and other systems, tools or devices that Customers manage or monitor using our Services, and end user data related to individuals activities on Customer’s network and systems. It may also include event logs, end user information (such as IP address, email address and computer name), and other data where relevant to a support or service request. We process Customer Data on the basis of instructions from our Customers. If we receive a data subject request, we shall forward it to our Customer, as the Customer is the controller of the Customer Data.

Usage Details. We collect information about Customers’ usage of our Services, including IP address, Customer ID, email address, and other usage statistics. We do not collect usage details about end users, except as necessary for support or to provide the Services requested by Customers (in which case we are a data processor of such data).

Information We Collect Automatically. In addition, our web servers may automatically collect website usage information from you when you visit our Website. Website usage information informs us about how visitors and subscribers use and navigate the Website, including the number and frequency of users to each web page, their IP address, and the length of their stays. See further information below under ” Information Gathering Tools “.

Profiling. We may analyze your personal information to create a profile of your interests and preferences so that we can contact you with relevant information as noted above. In some cases, we may make use of additional information about you from external sources to help us do this effectively.

Other Data. Centerity collects, uses and maintains certain data related to its business and the Services it provides to Customers, which is not personal data – this privacy notice does not restrict our use and processing of such data.

Information Gathering Tools.

We use commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate our Website (“Information Gathering Tools”). This section describes the types of Information Gathering Tools used on our Website and how this information may be used.

Cookies. We use cookies to make interactions with the Website easy and meaningful. When you visit the Website, our servers send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your Web browser. Unless you choose to identify yourself to us, either by responding to a promotional offer, opening an account, or filling out a Web form, you remain anonymous to us.

We use cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your Web browser’s ability to accept cookies, you will be able to navigate our Website, but some features of the Services may not work.

Web Beacons. We use Web beacons alone or in conjunction with cookies to compile information about Customers and visitors’ usage of the Website and interactions with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, we may place Web beacons in marketing emails that notify us when you click on a link in the email that directs you to our Website. We use Web beacons to operate and improve the Website and email communications.

IP Addresses. When you visit the Website, we collect your Internet Protocol (“IP”) addresses to track and aggregate non-personal information. For example, we use IP addresses to monitor the regions from which customers navigate the Website. We also collect IP addresses from Customers when they log into the Services.

Information collected by cookies and similar technologies are treated as non-personal information except to the extent under local law that IP addresses (or like identifiers) are otherwise considered Personal Information.

How We Use the Information Collected

We use your personal data to:

Deliver Services and support;
Send communications to you, such as service information, account summaries, promotional offers, and surveys;
Customize, analyze, and improve our services and communication with you;
Contact you as you have requested related to your services, employment application, or other inquiry;
Protect the security or integrity of the Website, our business, or our products or services; or
Otherwise, as disclosed to you at the point of collection.
In support of the above uses, we may combine the personally identifiable information you have provided to us on the Website with other information about you that is available to us, including Website usage information and information from other sources.

For individuals in the European Union, our processing (i.e., use) of your personal data is justified on the following legal bases:

Performance of Contract: the processing is necessary to perform a contract with you or take steps to enter into a contract at your request;
Compliance with Law: the processing is necessary for us to comply with a relevant legal obligation (for example, laws which require us to collect tax information from customers, carry out checks on customers, or which compel us to disclose information to public authorities or regulators);
Our Legitimate Interests: the processing is in our legitimate interests, subject to your interests and fundamental rights, and notably our legitimate interest in using applicable data to conduct and develop our business activities, such as developing and maintaining relationships with our customers (the majority of the processing covered by this notice is legitimate interest based);
Defend Our Rights: where the processing is necessary to the establishment, exercise or defense of legal claims; or
With Your Consent: you have consented to the processing (for example, where we are required by local law to rely upon your prior consent for the purposes of direct marketing).

Sharing of Information Collected

Service Providers and Partners. We may share your information with our contracted service providers and partners so that these service providers can provide services on our behalf. Unless described in this Privacy Policy, we do not share, sell, rent, or trade any information with third parties for their promotional purposes. For EU data, such processing is in our legitimate interest in ensuring that you may receive the Services you request from us. We contractually require agents, service providers, and affiliates who may process personal data related to the Services to provide the same level of protections for personal data as we use.

To Affiliates. To facilitate our global operations, in order to help us improve the content of the Website and to provide you with the products or services requested, we may transfer the collected information to our affiliates worldwide.

Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your personal data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.

Law Enforcement or National Security. In accordance with our legal obligations, we may also transfer Customer Data, subject to a lawful request, to public authorities for law enforcement or national security purposes.

International Transfer of Information Collected. To facilitate our global operations, we may transfer and process your data from around the world, including the United States. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries and territories, which may have different privacy laws from your country of residence. This Privacy Policy shall apply even if we transfer data to other countries. If we transfer Personal Data about you outside of the European Economic Area (except if an Adequate Country), we shall in advance of any such transfer ensure that a legal mechanism to achieve adequacy in respect of that processing is in place, such as the requirement for execution of Standard Contractual Sections as further described in our Data Processing Addendum located at Sharepoint/Centerity-US/Documents/GDPR.

Your Choices, Access and Update Your Information

Where lawful to do so, and subject to your consent where required, we may communicate with Customers (and related business contacts) about our Services. We will not contact you for sales or marketing purposes – either by email or phone – unless you have given your prior consent either directly to Centerity Systems, or to a third-party to which you have given consent to share your data. You can change your marketing preferences at any time or notify us that you do not want to receive communications from us as described above by contacting us by email at info-us@centerity.com or by phone at +1-339-225-6064.

Security

We are committed to protecting the security of your personal information. We use a variety of administrative, technical, and physical security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. We will not give, sell, rent, share, or trade any personal information about you to third parties or provide your personal information, including your name or electronic mail address, to third parties except as provided herein, or required by law, subpoena or court order. We will share aggregated demographic information with our partners and advertisers. This is not linked to any personal information that can identify any individual person.

If you have any questions about the security of your personal information, you can contact us at info-us@centerity.com

Access and Data Subject Rights

Individuals have the right to access the personal data processed about them, subject to applicable law; individuals may request to access their personal data processed by us by emailing us at info-us@centerity.com

Subject to applicable law, you may also have some or all of the following rights available to you in respect of your personal data:

to obtain a copy of your personal data together with information about how and on what basis that personal data is processed;
to rectify inaccurate personal data (including the right to have incomplete personal data completed);
to erase your personal data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed);
to restrict processing of your personal data under certain circumstances;
to port your data in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of a contract with you;
to withdraw your consent to our processing of your personal data (where that processing is based on your consent); and
to obtain, or see a copy of the appropriate safeguards under which your personal data is transferred to a third country or international organization.

In addition to the above rights, under EU data protection law, applicable individuals have the right to object, on grounds relating to your particular situation, at any time to any processing of your personal data for which we have justified on the basis of a legitimate interest, including profiling (as opposed to your consent) or to perform a contract with you. You also have the right to object at any time to any processing of your personal data for direct marketing purposes, including profiling for marketing purposes.

You also have the right to lodge a complaint with your local supervisory authority for data protection.

In relation to all of these rights, please contact us at info-us@centerity.com. Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, especially if your request is manifestly unfounded or excessive. We will endeavor to respond to your request within all applicable timeframes.

If you contact us regarding Customer Data for which we are a data processor, we will attempt to refer your request to the relevant Customer, and data controller for your personal data.

Links to Other Websites

Centerity Systems websites may contain links to other websites run by other organizations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

Retention of Your Personal Data

We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. However, in some circumstances, we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.

In specific circumstances, we may also retain your personal data for longer periods of time corresponding to a statute of limitation, so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

Review of This Policy

We keep this Policy under regular review. This Privacy Policy was last updated in August 2018.

Since we may change this Privacy Policy from time to time, please check back occasionally to ensure that you are satisfied with any changes. By using our websites, you are agreeing to be bound by this Privacy Policy.

Any questions regarding this Privacy Policy and our privacy practices should be sent by email to info-us@centerity.com or by writing to Centerity Systems Inc., 154 Wells Ave., Suite 4, Newton, MA 02459, USA. Alternately you may contact us by phone at +1-339-225-6064.