Version: May 24, 2018
1. Data controller
Personal Data processedWhen you use the Website, Reliant Technology will collect and process information regarding you (as an individual) which allows you to be identified either by itself, or together with other information which has been collected. Reliant Technology may also be able to collect and process information regarding other persons in this same manner, if you choose to provide it to Reliant Technology. This information may be classified as “Personal Data” and can be collected by Reliant Technology both when you choose to provide it (e.g., when you sign up for an account, in order to receive Reliant Technology’s Services) or simply by analysing your behaviour on the Website. Personal Data which can be processed by Reliant Technology through the Website are as follows:
a. Name, contact details and other Personal Data
In various sections of the Website – e.g. if you decide to request a quote on the Website, or to subscribe to the Website’s Blog – you will be asked to submit information such as your name, phone / mobile numbers and e-mail address, as well as information related to the company you currently work for and your position in that company. In addition, whenever you participate in surveys and other promotions which may be available on the Website, as well as whenever you communicate with Reliant Technology through the contact details provided in the Website, Reliant Technology may collect additional information which you choose to provide. This is also the case regarding any information you choose to disclose in certain sections of the Website which allow you to participate in a public forum or to contact Reliant Technology directly.
b. Special categories of Personal Data
Certain areas of the Website include free text fields where you can write messages to Reliant Technology (e.g., the Live Chat), or otherwise allow you to post various types of content on the Website, which may contain Personal Data. Where these fields are completely free, you may use them to disclose, or may post content which discloses (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation. Reliant Technology asks that you do not disclose any sensitive Personal Data on the Website, unless you consider this to be strictly necessary. If you do, then this Personal Data may be processed by the Company based on your explicit consent.
c. Other persons’ Personal Data
As mentioned in the previous section, certain areas of the Website include free text fields where you can write messages to Reliant Technology, or otherwise allow you to post various types of content on the Website. These messages and content may (inadvertently or not) include Personal Data related to other persons. In any situation where you decide to share Personal Data related to other persons on the Website, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Reliant Technology against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website. As Reliant Technology does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to Reliant Technology; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give Reliant Technology this information.
d. Browsing data
The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Reliant Technology does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data. This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on. These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website.
- Types of cookies used by the Website
The Website use the following types of cookies: Browsing or session cookies, which are strictly necessary for the Website’s operation, and/or to allow you to use the Website’s content and Services. Analytics cookies, which allow Reliant Technology to understand how users make use of the Website, and to track traffic to and from the Website. Function cookies, which are used to activate specific Website functions and to configure the Website according to your choices (e.g., language), in order to improve your experience. Profiling cookies, which are used to observe the preferences you reveal through your use of the Website and to send you advertising messages in line with those preferences. Reliant Technology also uses third-party cookies – i.e. cookies from websites / web servers other than the Website, owned by third parties. These third parties will either act as independent data controllers from Reliant Technology regarding their own cookies (using the data they collect for their own purposes and under terms defined by them) or as data processors for Reliant Technology (processing personal data on Reliant Technology’s behalf).
- Cookie settings
You can block or delete cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions: Internet Explorer Firefox Chrome Safari CAUTION: If you block or delete technical and/or function cookies used by the Website, the Website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website. Reliant Technology uses Google Analytics on the Website. This is a tool developed by Google and used to collect information, which permits evaluation of the use of the Website, analysis of your behaviour and improvement of your experience with the Website. You can obtain more information about how to opt out of Google Analytics at: https://tools.google.com/dlpage/gaoptout.
2. Purposes of processing
Reliant Technology intends to use your Personal Data, collected through the Website, for the following purposes:
- To verify your identity and assist you, in case you lose or forget your login / password details for any of Reliant Technology’s registration services, to allow you to access different restricted areas and sections of the Website (such as the Customer Portals), to request quotes, to send messages to Reliant Technology, and to provide any other Services which you may request (“Service Provision”);
- For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail and/or SMS (“Marketing”);
- To create a profile of you as a Website user, through the use of profiling cookies and by collecting and analysing information on the preferences you select and choices you make in the Website, as well as your general activities on the Website. This profile will be used to give you information about other websites / services which Reliant Technology believes you may be interested in, and to show you information and advertisements which may be relevant to you and your interests. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias (“Profiling”);
- For compliance with laws which impose upon Reliant Technology the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
- For development and administration of the Website, in particular by use of data analytics regarding how you and other users use the Website, as well as the information and feedback you provide, to improve our offerings (“Analytics”);
- To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”).
3. Grounds for processing and mandatory / discretionary nature of processing
Reliant Technology’s legal bases to process your Personal Data, according to the purposes identified in Section 3, are as follows:
- Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Reliant Technology your Personal Data for these purposes; however, if you do not, Reliant Technology will not be able to provide any Services to you.
- Profiling: processing for this purpose is based on your consent, given by accepting the use of profiling cookies. It is not mandatory for you to give consent to Reliant Technology for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Website). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
- Compliance: processing for this purpose is necessary for Reliant Technology to comply with its legal obligations. When you provide any Personal Data to Reliant Technology, Reliant Technology must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
- Analytics: Information collected for this purpose is used to allow Reliant Technology to understand how users interact with the Website and to improve the Website accordingly, with the aim to providing a better user experience.
- Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes).
4. Recipients of Personal Data
Your Personal Data may be shared with the following list of persons / entities (“Recipients”):
- Persons, companies or professional firms providing Reliant Technology with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services;
- Entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers);
- Persons authorised by Reliant Technology to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
- Persons authorised by Reliant Technology to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g.,employees of Reliant Technology);
- Other companies within the Reliant Technology Group; and
- Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
5. Transfer of Personal Data
Considering Reliant Technology’s worldwide presence and business operations, your Personal Data may be transferred to Recipients located in several different countries. Reliant Technology implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand.
6. Retention of Personal Data
Personal Data processed for Service Provision will be kept by Reliant Technology for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, Reliant Technology may continue to store this Personal Data for a longer period, as may be necessary to protect Reliant Technology’s interests related to potential liability related to the provision of the Services. Personal Data processed for Marketing will be kept by Reliant Technology until you opt-out or unsubscribe. Once this is done, Personal Data will no longer be used for these purposes, although it may still be kept by Reliant Technology, in particular as may be necessary to protect Reliant Technology’s interests related to potential liability related to this processing. Personal Data processed for Profiling will be kept by Reliant Technology from the moment you give consent until the moment you withdraw the consent given. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by Reliant Technology, in particular as may be necessary to protect Reliant Technology’s interests related to potential liability related to this processing. Personal Data processed for Compliance will be kept by Reliant Technology for the period required by the specific legal obligation or by the applicable law. Personal Data processed for Analytics and Misuse/Fraud will be kept by Reliant Technology for as long as deemed strictly necessary to fulfil the purposes for which it was collected, unless you validly object to the processing of your Personal Data for these purposes (please see Section 8 for further information).
7. Data subjects’ rights
As a data subject, are entitled to exercise the following rights before Reliant Technology, at any time:
- Access your Personal Data being processed by Reliant Technology (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
- Correct or update your Personal Data processed by Reliant Technology, where it may be inaccurate or incomplete;
- Request erasure of your Personal Data being processed by Reliant Technology, where you feel that the processing is unnecessary or otherwise unlawful;
- Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
- Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Reliant Technology, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
- Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Reliant Technology from processing your Personal Data; or
- Withdraw your consent to processing (for Profiling).