Last updated: January 31, 2019
- Information we collect about you
- Cookies and other technologies
- How we use your information
- Our promotional updates and communications
- Who we give your information to
- Where we store your information
- Child safety
- How we protect your information
- How long we keep your information
- Your rights
- Changes to this policy
- Contact us
Information we collect about you
We will collect and process the following personal data from you:
Information you give us
This is information about you that you give us directly when you interact with us.
This is information about you that you give us by filling in forms on our Sites or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Sites, subscribe to our services, search for a product or service, place an order on our Sites, participate in discussion boards or other social media functions on or via our Sites, enter a competition, promotion or survey, submit a query, and when you report a problem with our Sites.
The information you give us may include your name, address, e-mail address and phone number, login and password details.
It may also include employment details if you send us a Cover Letter, resumé or other details of your employment history in connection with an advertised job vacancy or a general enquiry regarding employment opportunities with us.
Information we collect about you from your use of our Sites:
We will automatically collect information from you each time you visit our Sites.
- Technical information
- Information about your visit
- Location data
Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our Sites (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
Location data - we collect information through the Sites as to your real-time location to provide location services where requested or agreed to by you in order to deliver content, that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the Site.
Information we receive from other sources.
This is information we receive about you:
- If you use any of the services we provide.
- From third parties we work closely with (customers to which we provide services which in turn provide service to you).
In this case we will have informed you when we collected that data if we intend to share your data internally and combine it with data collected on our Sites. We will also have told you for what purpose we will share and combine your data.
We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers).
Cookies and other technologies
A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser. Others are used to remember you when you return to our Sites and will last for longer.
We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.
Our partners, affiliates, and customers also use technologies such as cookies or similar technologies to analyze trends, administer the website, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
- Strictly necessary cookies. These are cookies that are required for the operation of our Sites and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our Sites.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Sites when they are using them. This helps us for our legitimate interests of improving the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our Sites. This enables us, subject to your choices and preferences, to personalise our content and remember your preferences (for example, your choice of language or region).
- Targeting/Advertising cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Sites and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
We may also work with advertising networks that gather information about your interaction with the content on our Sites and on information on other websites and services you visit. This may result in you seeing our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit http://www.youronlinechoices.eu in the UK or in the US http://optout.networkadvertising.org
The effect of disabling cookies depends on which cookies you disable but, in general, the Sites may not operate properly if all cookies are switched off.
If you want to disable cookies on our Sites, you need to change your web browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below: -
For Microsoft Internet Explorer:
1. Choose the menu “tools” then “Internet Options”
2. Click on the “privacy” tab
3. Select the setting the appropriate setting
For Google Chrome:
1. Choose Settings> Advanced
2. Under "Privacy and security," click “Content settings”.
3. Click “Cookies”
1. Choose Preferences > Privacy
2. Click on “Remove all Website Data”
For Mozilla Firefox:
1. Choose the menu “tools” then “Options”
2. Click on the icon “privacy”
3. Find the menu “cookie” and select the relevant options
For Opera 6.0 and further:
1. Choose the menu Files”> “Preferences”
Except for essential cookies, all cookies used on our Sites will expire after 2 years.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our Sites (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data.
How we use your information
You can see a full list of the types of data we process through our Sites, the purpose for which we process it and the lawful basis on which it is processed here.
We use information held about you in the following ways:
Information you give to us:
We will use this information to:
- Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us including:
- conducting credit checks;
- administering your account with us;
- verifying and carrying out financial transactions in relation to payments you make;
- notifying you about changes to our products and services.
- Provide you with information about our services we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See 'Our promotional updates and communications'.
- Display personal testimonials of satisfied customers on our Sites in addition to other endorsements. With your consent we may post your testimonial along with your name.
- Ensure in our legitimate interests that:
- content from our Sites are presented in the most effective manner for you and for your computer.
- we provide you with the information, products and services that you request from us.
Information we collect about you from your use of our Sites
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- To administer our Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To keep our Sites safe and secure.
- For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- To improve our Sites to ensure that content is presented in the most effective manner for you and for your computer.
Information we receive from other sources
We may combine information from other sources with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights).
Information collected through our services to clients
accesso collects information under the direction of its clients and has no direct relationship with the individuals whose personal data it processes.
If you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our clients.
accesso will retain personal data we process on behalf of our clients for as long as needed to provide services to our client. accesso will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to accesso’s client (the data controller). If the client requests accesso to remove the data, we will respond to their request within a reasonable timeframe.
Our promotional updates and communications
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our products/services. You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to PrivacyContact@accesso.com.
Who we give your information to
We may give your information to:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy.
- Selected third parties.
Our selected third parties may include:
- Organisations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes in supporting the services we offer through the Sites in particular those providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services and providing IT support services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We may make use of the personal data we have collected from you to enable us to display our advertisements to you on other websites and subject to the cookie section of this policy.
- Analytics and search engine providers that assist us in the improvement and optimisation of our Sites and subject to the cookie section of this policy (this will not identify you as an individual).
- Business partners who jointly with us provide services to you and with whom we have entered into agreements in relation to the processing of your personal data. If you do not want us to share your personal information with these companies, please contact us at PrivacyContact@accesso.com
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
- Payment processing providers who provide secure payment processing services.
We will disclose your personal information to third parties:
- If accesso or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, such as to comply with a subpoena or other legal process, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of accesso, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
Where we store your information
We may transfer your personal information outside the EEA:
- In order to store it.
- In order to enable us to provide services to you and fulfil our contract with you or a customer. This includes order fulfilment, processing of payment details, and the provision of support services.
- Where we are legally required to do so.
- In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
EU – U.S. Privacy Shield and Swiss - U.S. Privacy Shield
accesso participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are 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. https://www.privacyshield.gov
accesso 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. We comply 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, accesso is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, accesso may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
We will not ask for information from children under 13 years of age. Teenagers should ask their parents for permission before sending any information about themselves (name, address, e-mail address, etc.) to us or anyone else over the Internet.
How we protect your information
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using TLS 1.2. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Our Sites may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites. We encourage you to review those third parties' privacy policies and ask them questions about their privacy practices as they relate to you.
How long we keep your information
We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
- If you are based in the EU you have the right under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data, including the right to object to marketing;
- to request that your provided personal data be moved to a third party.
- Wherever you are based you may:
- opt out at any time from allowing further access by us to your location data in the settings of the device you use to access the Sites.
- update or delete a testimonial you have allowed us to publish on the Sites, you can contact us at PrivacyContact@accesso.com; and
- Where the processing of your personal information by us is based on consent (for example If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you), you have the right to withdraw that consent without detriment at any time by contacting us PrivacyContact@accesso.com.
We may also send you service related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature.
You can also exercise the rights listed above at any time by contacting us at PrivacyContact@accesso.com.
Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Changes to this policy
Attn: C. Michael Wiggins
Director, Compliance and Payments
Accesso Technology Group PLC
1025 Greenwood Blvd
Lake Mary, FL 32746