Critical Research Privacy Shield Statement
Last Updated April 15, 2019
This EU-US Privacy Shield Statement applies to all Personal Data (defined below) that is received by Critical Research in the US from the EEA. Critical Research commits to comply with the Privacy Shield Principles in respect of such Personal Data.
3. Types of Personal Data Collected
When you interact with us through our Services, we may collect Personal Data and other information from you, as further described below:
A. PERSONAL DATA THAT YOU PROVIDE THROUGH THE SERVICES
We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services.
B. PERSONAL DATA THAT WE RECEIVE FROM OUR CUSTOMERS
In addition to our own data processing involving Personal Data, Critical Research may process certain Customer data at the direction of our Customers which may potentially include Personal Data. Critical Research may cache this data and various aggregations and transformation (charts, graphs, maps, tables, dashboards, etc.) as part of normal operations as covered by our Subscription Services Agreement. In such instances, Critical Research is acting as the data processor on behalf, and pursuant to the instructions, of our Customers, who act as the data controller (an entity that determines the purposes and means for processing personal data). If you have any questions about our processing of this information, you are advised to contact the Critical Research’s Customer who has directed us to process the particular information.
C. OTHER INFORMATION
Non-Identifiable Data: When you interact with Critical Research through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Critical Research may store such information itself or such information may be included in databases owned and maintained by Critical Research affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Sites, the number of visitors to each page of our Sites, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.
Service Data: In order to provide our Services, our software must collect information from network-connected equipment and transfer this information to the Critical Research for processing, analysis, and display within the product user interface. This information includes the type and quantities of equipment, DNS names, IP addresses, MAC addresses, and other information about the connected equipment, such as running services and installed software. The software also collects minimal information about the equipment on which it is installed; this includes the hostname, domain name, operating system, installed software, and service process environment, as well as hardware information, such as the processor model, memory, storage, and network interfaces. This information is used to enable functionality within the Service and assist with support requests.
4. Our Use of Your Personal Data and Other Information
5. Our Disclosure of Your Personal Data and Other Information
Critical Research may disclose Personal Data to third-party service providers (such as providers of customer and lead management services, email communication and customer support services) and subcontractors (such as providers of compute and storage resources) who perform certain services or provide certain solutions on our behalf and under our instructions as necessary in connection with the performance of requested services or solutions. Critical Research maintains contracts with these third parties restricting their access, use and disclosure of Personal Data in compliance with the Privacy Shield Principles.
Critical Research may also disclose Personal Data as necessary in connection with the sale or transfer of all or part of its business.
Critical Research may also disclose Personal Data as required or permitted by law, or when Critical Research believes that disclosure is necessary to protect its rights or to comply with a judicial proceeding, a court order, a law enforcement request, or other legal process, or lawful requests by public authorities, including to meet national security or law enforcement requirements.
In addition to the above, we may share Personal Data about you with others to the extent you consent to such sharing.
Critical Research will offer individuals the opportunity to choose (opt out) whether their Personal Data is (a) to be disclosed to third parties, except when disclosure is made to a third party that is acting as an agent to perform task(s) on our behalf and under our instructions or (b) to be used for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized by the individual. Critical Research will provide individuals with clear, conspicuous and readily available mechanisms to exercise their choices should applicable circumstances arise. In order to request that Critical Research not use an individual’s Personal Data, such individual should contact Critical Research by email at: firstname.lastname@example.org. Individuals may also opt out of receiving marketing messages from Critical Research by notifying Critical Research at: email@example.com.
7. Data Integrity and Purpose Limitation
Consistent with the Privacy Shield Principles, we will limit collection of Personal Data to the information that is relevant for the purposes of processing and we will not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. To the extent necessary for those purposes, we will also take reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete and current. We will adhere to the Privacy Shield Principles for as long as we retain Personal Data about you.
8. Accountability for Onward Transfer
Pursuant to the Privacy Shield Principles, Critical Research remains accountable for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party agent. In particular, Critical Research remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless Critical Research proves that it is not responsible for the event giving rise to the damage.
We are committed to securing all Personal Data provided to us. We have deployed and maintain reasonable and appropriate process and technology measures to provide reasonable assurance that your Personal Data is secured against loss, misuse and unauthorized access, disclosure, alteration and destruction.
Upon request, Critical Research will grant individuals reasonable access to Personal Data that it holds about them. In addition, Critical Research will take reasonable steps to permit individuals to correct, amend, or delete information where it is inaccurate, or has been processed in violation of the Privacy Shield Principles. Critical Research will process all reasonable requests for access within a reasonable time period, but reserves the right to restrict access in cases where the legitimate rights of persons other than the individual would be violated or where the burden or cost of providing access would be disproportionate to the risks to the individual’s privacy.
11. Recourse; Enforcement
In compliance with the Privacy Shield Principles, Critical Research commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Critical Research at: firstname.lastname@example.org
Critical Research has further committed to refer unresolved Privacy Shield complaints to the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR/AAA), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you.
With respect to Personal Data received or transferred pursuant to the Privacy Shield framework, Critical Research is subject to the regulatory enforcement powers of the US Federal Trade Commission.
In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles.
If you have any questions, comments or concerns about our privacy practices, please contact us via email using the address email@example.com.