Last Modified: June 11, 2019
For purposes of the European Union General Data Protection Regulation (GDPR), Soroco is the data controller of personal information collected by it via the Site.
What is Personal Information?
As used in this policy, “personal information” means any information that may be used, either alone or in combination with other information, to identify an individual. When we combine any non-personal information with personal information (e.g., technical information, such as the type of browser or operating system that you use), we treat the combined information as personal information.
Collection of Personal Information
- Personal Information You Provide to Us
Soroco may collect certain personal information when someone voluntarily sends a direct mail inquiry, an email or online registration, registers to download documents from the Sites, participates in seminars or webinars, requests Company information at tradeshows, applies for a job via the Sites, requests information, or purchases goods or services, via the Sites. Examples of such personal information include, but are not limited to, individual names, telephone numbers, email addresses, company name, mailing address, account username and password, job title and financial information such as a credit or debit card number. If you apply for a job via the Sites, we may also collect personal information via your resume or any cover letter you choose to upload, or via any social media profile to which you elect to provide access. We process personal information you provide to us either in connection with our legitimate business interests, or to the extent necessary for the performance of a contract with you, your company, or our customers.
- Personal Information Collected Through Cookies and Similar Technologies Soroco may collect certain information, including personal information, automatically from visitors to its Sites, and those of its subsidiaries, including the IP address, time visited, pages viewed and related information. When you visit the Sites, open emails from Soroco, use its apps or interact with its related tools, widgets or plug-ins, Soroco may collect certain information by automated means, such as through cookies, web beacons and web server logs. The information collected in this manner may include your IP address, unique device identifier, browser characteristics, domain, and other system settings, search queries, device characteristics, operating system type, language preferences, referring URLs, actions take on the Sites, dates and times of Site visits, metadata and other information associated with other files stored on your device.
Soroco uses Hotjar for qualitative customer analysis. For more information on how Hotjar processes personal information, please see https://www.hotjar.com/. You can opt out of Hotjar by visiting the following link: https://www.hotjar.com/legal/compliance/opt-out .
Soroco uses Google Analytics for quantitative customer analysis. For more information on how Google Analytics processes personal information, please see https://analytics.withgoogle.com/. You can opt out of Google Analytics by using the following browser plugin: https://tools.google.com/dlpage/gaoptout .
We process personal information collected through cookies or similar technologies either in connection with our legitimate business interests in operating the Sites, performing the services, or operating our business, or otherwise to the extent you have agreed that we may do so.
- Personal Information Collected Through Use of Our Services
Soroco may collect certain personal information that is provided in the course of the use of our services. This includes personal information contained in semi-structured and unstructured data hidden in electronic documents, images, and emails provided by our customers when using our services. This data will be processed for the purposes of operating our Sites and providing our services. We also use this data for our internal training and quality purposes, and to enhance, research and analyze our service offerings and models. Examples of such personal information include, but are not limited to, individual names, telephone numbers, email addresses, job titles and contact information contained in invoices or emails. Personal information may relate to our customer’s employees, contractors or their customers or service providers. The legal basis for processing this personal information is (i) our legitimate interests namely performing our services, or monitoring and improving our Sites and services, or (ii) necessity for the performance of a contract between you, your company or our customer, and us. We will retain such personal information only for so long as we have a lawful basis to process it, as set forth in this policy and with respect to (a) personal information processed by us in connection with our provision of support services, within 90 days after the associated help desk ticket is closed, and (b) all other personal information collected through use of our services, within (30) days after the termination of the applicable contract between you, your company or our customer and us.
Uses of Personal Information
Soroco uses your personal information to monitor the performance, and improve the quality of, its Sites, respond to requests about the Company and its business, provide information about products and services, fulfill customer requests and for other business purposes and/or to comply with various legal and regulatory obligations. With your consent, Soroco may also use your personal information to send you information about its other products and services and for other specified marketing purposes. Unless we obtain your consent to the processing of your personal information, Soroco processes your personal information either for the performance of a contract with you or in circumstances where it has a legitimate interest to do so.
Soroco may use information collected through cookies, web beacons, pixels, web server logs and other automated means for purposes such as (a) customizing user visits to the Sites, (b) delivering content tailored to users’ interests and the manner in which our users browse the Sites, and (c) managing the Sites and other aspects of its business. You can change your cookies settings in your browser, however, please note that without cookies you may not be able to use all the features of the Sites. For more information about the cookies we use on the Sites, please click here.
Sharing of Personal Information
Soroco may share your personal information with its affiliates and subsidiaries, and/or with its business partners, in order to respond to customer needs or otherwise provide services to customers as requested. Soroco may also, with your consent, engage in joint marketing activities with such third parties and/or disclose personal information to third parties for their own direct marketing purposes.
Soroco may also share your information with its third-party agents who may be acting on its behalf and pursuant to its instructions to assist in our business activities, including, for example, providing notice of an upcoming webinar or tradeshow that may be of interest to the target audience, providing customer service, payment processing or providing storage services.
Soroco may disclose your personal information if it is required to do so by law or court order, to enforce or apply its Terms or if it believes in good faith that such release is necessary or appropriate to protect the rights, property, or safety of its company, customers, affiliates or others.
Soroco also may share or transfer information, including your personal information, in connection with the sale, transfer, acquisition, merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by Soroco or any affiliated company (in each case, whether in whole or in part). When one of these events occurs, Soroco will use reasonable efforts to notify users before their personal information is transferred or becomes subject to different privacy practices.
Soroco may sometimes partners with other companies in order to provide their services via a link on the Site, for example, job applications and social media links. In those circumstances, the third-party partners may have access to the personal information you provide to them via their website, and we do not have any control over how they use that personal information. In order to fully understand how your personal information is used by our partners, please carefully review their applicable privacy policies. Except as set forth herein, Soroco does not share your personal information with any third parties.
Other Uses of Personal Information
In addition to the uses described above, Soroco will inform individuals of any other intended uses of their personal information at the time such personal information is collected or before such use is implemented including disclosure to third parties.
Data Security and Retention
Soroco uses reasonable methods to secure all personal information by a variety of methods, including restricting access to such personal information only to those people who have a legitimate need to know in order to discharge their job responsibilities on behalf of Soroco, securing access to the facility where the personal information is stored and the use of technology and physical controls to secure the personal information. Soroco is required to disclose personal information in response to lawful requests by public authorities including to meet national security or law enforcement requirements. If you have questions about the security of your personal information, please contact us as described below.
Security of Personal Information by Third Parties
Soroco will require that all third parties acting on behalf of Soroco, and to which personal information is provided, give Soroco adequate contractual assurances that they will safeguard all such personal information in a manner consistent with this policy.
Children under the age of 18
The Sites are not intended for minors under the age of 18. Accordingly, we do not intend to collect personal information from anyone we know to be under 18 years of age.
Advertising and Newsletters
We will use your personal information to send you email or newsletters if you have signed-up to receive them. If you would like to discontinue receiving this information, you may update your email preferences by using the “unsubscribe” link found in emails we send to you, or at your member profile on our website, or by contacting us as described below. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).
Upon an individual’s request, Soroco will provide reasonable access to any personal information it has about that person. Soroco will also take reasonable steps to allow such individuals to correct, change, modify or delete any such personal information that is shown to be incorrect, inaccurate or incomplete. You may ask us to delete the personal information we hold about you or cease processing such personal information, in certain circumstances. It may not be possible for us to delete or cease processing all the personal information we hold about you where we have an ongoing relationship with you or where we have a legal basis to retain such personal information.
You may access, correct, or request deletion of your personal information by logging into your account or by contacting us at firstname.lastname@example.org. We will respond to your request within a reasonable timeframe.
When we process personal information on the basis that you have consented to such processing, you have the right to withdraw your consent or ask us to stop or restrict processing the personal information we have about you, at any time by contacting us using the contact information below.
You may also ask us to transfer your personal information to a third party in certain circumstances. If you would like any further information about your rights or how to exercise them, please contact us using the contact information below.
If you are in the European Union, you have the right to make a complaint at any time to the relevant data protection authority in your country. We encourage you to first reach out to us at email@example.com.
Personal information collected by Soroco may be stored and processed in your geographic region, in the United States or in other countries in which Soroco, or its service providers, maintain facilities or operations. If you are in the European Economic Area, it may be necessary for your personal information to be transferred to, and processed in, other countries including the United States. If we transfer your personal information outside of the European Economic Area, we use a variety of legal mechanisms, which may include contractual terms, to protect your rights with respect to your personal information.
We do not track users over time and across third-party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an individual consumer’s online activities over time and across third-party web sites or online services.
Your California Privacy Rights
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information (as defined by California law) by Soroco to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write to us using the contact details below.
Soroco may amend or modify this policy from time to time. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by posting the amended or modified version on its website at www.soroco.com. This policy may also be changed, or limited, to comply with legal or regulatory requirements, or as otherwise allowed or required by law.
Questions or comments about this policy, or concerns or complaints about possible violations, should be sent to email@example.com or to:
Soroco Americas Private Limited
Attn: Legal Counsel
101 Arch Street, Suite 2100
Boston, MA 02110
United States of America
Our European representative, as required by the European Union General Data Protection Regulation (GDPR), can be contacted at firstname.lastname@example.org or:
Soroco Private Limited
Attn: Privacy Office/Legal Department
London, EC2N 3AR