SYSTEMATIC PRIVACY POLICY

Last Modified: May 24, 2018

 

We at SystematIC are committed to protecting your privacy. This Privacy Policy applies to our website (www.Systemat-IC.com) owned and controlled by SystematIC. This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the website.

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification. While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at [email protected] or by mail to SystematIC, Elektronicaweg 20, 2628 XG Delft, The Netherlands.

INFORMATION WE COLLECT

WHEN YOU VISIT OUR WEBSITES

You are free to explore the Website without providing any Personal Information about yourself. When you visit the Website or register for the newsletter, we request that you provide Personal Information about yourself, and we collect Navigational Information.

We use analytics software to allow us to better understand the functionality of our website. This software may record information such as how often you use the website, the events that occur within the website, aggregated usage, performance data, and how you found the website.

We may link information we store within the analytics software to Personal Information you submit within the Website. We do this to improve services we offer you and improve our marketing, analytics and site functionality.

"PERSONAL INFORMATION"

This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions that you enter into on the Websites, and information about you that is available on the internet, such as from LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.

Personal Information also includes Navigational Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the "Navigation Information" section below. Except for this, we do not collect Sensitive Information from you.

LOG FILES

When you use our services our view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by SystematIC to provide general statistics regarding use of the SystematIC Website. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.

INFORMATION WE COLLECT FROM THIRD PARTIES

From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.

INFORMATION ABOUT CHILDREN

The Websites is not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16 If you believe that we have collected information about a child under 16, please contact us at [email protected], so that we may delete the information.

HOW WE USE INFORMATION WE COLLECT

COMPLIANCE WITH OUR PRIVACY POLICY

We use the information we collect only in compliance with this Privacy Policy. Customers who subscribe to our newsletter are obligated through our agreements with them to comply with this Privacy Policy.

WE NEVER SELL PERSONAL INFORMATION

We will never sell your Personal Information to any third party.

USE OF PERSONAL INFORMATION

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:

- Improve your browsing experience by personalizing the Website;

- Send information or SystematIC content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;

- Promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;

- Provide other companies with statistical information about our users - but this information will not be used to identify any individual user;

- Send information to you regarding changes to our Customer Terms of Service, Privacy Policy (including the Cookie Policy), or other legal agreements

- Meet legal requirements.

Legal basis for processing Personal Information (EEA visitors only)

If you are a visitor/customer located in the European Economic Area ("EEA"), SystematIC is the data controller of your personal information. SystematIC’s Data Protection Officer can be contacted at [email protected]

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

USE OF NAVIGATIONAL INFORMATION

We use Navigational Information to operate and improve the Websites. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about SystematIC.

CUSTOMER TESTIMONIALS AND COMMENTS

We post customer testimonials and comments on our Website, which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial.

SECURITY OF YOUR PERSONAL INFORMATION

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.

SOCIAL MEDIA FEATURES

Our Website include Social Media Features, such as the LinkedIn button and Widgets or other interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Website. This Privacy Policy does not apply to these features.  Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

EXTERNAL WEBSITES

Our Website provides links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

RETENTION OF PERSONAL INFORMATION

How long we keep information we collect about you depends on the type of information, as described in further detail below.  After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about our services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

HOW WE SHARE INFORMATION WE COLLECT

We employ other companies and people to provide services to visitors to our Website and/or our customers and may need to share your information with them to provide information, products or services to you. Examples may include analyzing data or performing statistical analysis, providing marketing assistance, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.

PARTNERS

In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.

We partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you. When you engage with these co-marketing partners, we will tell you who we are sharing data with, and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications. These co-marketing partners are required to adhere to our privacy and data protection policies.

CORPORATE EVENTS

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by SystematIC on the Website. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.

COMPELLED DISCLOSURE

We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

INTERNATIONAL TRANSFER OF INFORMATION

INTERNATIONAL TRANSFERS

This Privacy Policy shall apply even if we transfer Personal Information to other countries. We have taken appropriate safeguards to require that your Personal Information will remain protected. When we share information about you within and among SystematIC affiliated entities, we make use of standard contractual data protection clauses, which have been approved by the European Commission, and we rely on the EU-U.S. and Swiss-U.S. Privacy Shield Framework to safeguard the transfer of information we collect from the European Economic Area and Switzerland. Please see our Privacy Shield notice below for more information.

INTERNATIONAL TRANSFERS TO THIRD PARTIES

Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the European Economic Area or Switzerland, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer. Please see our Privacy Shield Notice below.

PRIVACY SHIELD NOTICE

SystematIC participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework. The following affiliated entities adhere to the Privacy Shield principles: SystematIC. SystematIC is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.

SystematIC is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. SystematIC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, SystematIC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, SystematIC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

You may direct any inquiries or complaints related to our Privacy Shield compliance to [email protected]

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

HOW TO ACCESS & CONTROL YOUR PERSONAL DATA

REVIEWING, CORRECTING AND REMOVING YOUR PERSONAL INFORMATION

You have the following data protection rights:

- You can request access, correction, updates or deletion of your personal information.

- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

- You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available on http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

To exercise any of these rights, please contact us at [email protected] or by mail to SystematIC, Elektronicaweg 20, 2628 XG Delft, The Netherlands. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

ANTI-SPAM POLICY

In the context of electronic messaging, spam refers to unsolicited, bulk or indiscriminate messages, typically sent for a commercial purpose. SystematIC has a zero-tolerance spam policy.

In the unlikely event that you receive any message from SystematIC or sent using SystematIC systems that may be considered to be spam, please contact us at [email protected] or by mail to SystematIC, Elektronicaweg 20, 2628 XG Delft, The Netherlands and the matter will be investigated.

TO UNSUBSCRIBE FROM OUR COMMUNICATIONS

You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at [email protected] or postal mail to SystematIC, Elektronicaweg 20, 2628 XG Delft, The Netherlands.

COOKIES AND SIMILAR TECHNOLOGIES

COOKIES

SystematIC and its partners use cookies or similar technologies (such as web beacons) to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.

This Cookie Policy explains how SystematIC and our affiliates use cookies and similar technologies to recognize you when you visit the Website owned and controlled by SystematIC. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

WHAT ARE COOKIES?

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.

Cookies provide a convenience feature to save you time, or tell the Web server that you have returned to a specific page. For example, a cookie helps us to recall your specific information on subsequent visits. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the customized features.

Cookies set by the website owner (in this case, SystematIC) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

WHY DO WE USE COOKIES?

We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Websites. For example, SystematIC keeps track of the Website and pages you visit within SystematIC, in order to determine what portion of the SystematIC Website is the most popular or most used. This data is used to deliver customized content and promotions within the SystematIC Website to customers whose behavior indicates that they are interested in a particular subject area. Third parties serve cookies through our Website for advertising, analytics and other purposes. This is described in more detail below.

WHAT TYPES OF COOKIES DO WE USE AND HOW DO WE USE THEM?

The specific types of first and third party cookies served through our Website and the purposes they perform. These cookies include:

Essential website cookies: These cookies are strictly necessary to provide you with services available through our Website.

Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our Website but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, or to help us customize our Website for you.

Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.

Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Website through third party social networking and other websites. These cookies may also be used for advertising purposes too.

HOW CAN I CONTROL COOKIES?

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided below.

You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com. You may opt out by clicking here: http://www.youronlinechoices.eu. Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.

Essential website cookies: Because these cookies are strictly necessary to deliver the Website to you, you cannot refuse them. You can block or delete them by changing your browser settings however, as described above.

WHAT ABOUT OTHER TRACKING TECHNOLOGIES, LIKE WEB BEACONS?

Cookies are not the only way to recognize or track visitors to a website. We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage the Website and Subscription Service by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on Web pages or in emails and are about the size of the period at the end of this sentence. We use clear gifs or pixels in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our customers' Personal Information.

DO YOU URSE FLASH COOKIES OR LOCAL SHARED OBJECTS?

The Adobe Flash Player (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies but these are managed through a different interface than the one provided by your Web browser. This technology creates locally stored objects that are often referred to as "Flash cookies." SystematIC does not use Flash cookies.

HOW OFTEN WILL YOU UPDATE THIS COOKIE POLICY?

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this page regularly to stay informed about our use of cookies and related technologies.

WERE CAN I GET FURTHER INFORMATION?

If you have any questions about our use of cookies or other technologies, please email us at [email protected]