Version: February 6, 2020
All personal data we collect on the users of our website is handled in a lawful, fair and transparent manner. We follow internationally recognized principles on this, such as the principles of purpose limitation, storage limitation, data minimization, data quality, and confidentialty.
1. Data Controller
We are a data controller of all personal data that is collected and processed through our website.
2. Personal data processed
When you visit our website, we collect and process some personal data related to you, both when you decide to actively provide it to us (such as when you sign up to subscribe to our newsletter), and by analyzing your behavior on the website.
a. Name, contact details and other Personal Data
In various sections of the website (such as when request a quote, or sign up to our blog), we require you to send us some of your personal data, such as your name, phone / mobile number, e-mail address and information related to your employer, such as its name and your position.
When you participate in our surveys, promotions, and forums, as well as when you communicate with us using our provided contact details on the website, we may also collect additional personal data of yours, if you choose to provide it to us.
b. Special categories of personal data
Our website includes free text fields so you can send us messages (for example, the Live Chat function), as well as sections where you can post various types of content. You might include (whether on purpose or not) some of your own personal data within those messages or posts, including special categories of personal data.
We ask you to not disclose any personal data in the messages that you send to us or in any posts you make (particularly special categories of personal data!), unless you feel that this is strictly necessary. If you decide to do so, we will collect and process those personal data only where we believe we are legally allowed to do so, in order to address your message or post.
c. Personal data of other persons
Just as we explained above, the free text fields on our website can be used to send us messages or post various types of content. You might also include (whether on purpose or not) personal data related to other persons within those messages and posts.
If you disclose personal data of other people to us through our website, you will be considered as an independent data controller regarding those personal data. This means you will be held fully responsible for ensuring that you are allowed to disclose those personal data to us (for example, because the other people have agreed to this, or because you are legally required to do so). If you are not allowed to disclose those personal data to us, then you may be required to compensate us in full for any damages or costs we suffer because of this – for instance, as a result of complaints brought against us, or lawsuits filed against us.
d. Browsing data
Our website uses computer systems and software procedures that collect browsing data about users of the website, which includes your IP address, location, and more. We don’t collect this information to link it to specific users (though it is possible to identify specific users, using browsing data alone or by matching browsing data with other information we have). These browsing data are used to compile statistical information on the use of our website, make sure it works properly, and make sure that our website is not abused.
– What are cookies?
Cookies are small text files that are sent and registered on your computer by the websites that you visit. These files are then re-sent by your computer to the same sites, when you visit them again.
Cookies allow websites to “remember” your actions and preferences (such as login data, language, font size, browsing activities and more). The information collected by cookies can be used for a wide variety of purposes, including to ensure that you don’t need to reconfigure settings when you visit a website again (or when you change pages within the same site), to keep you logged in to your account, to gather information about how you use a website, and to display advertisements on a website which may interest you.
There are different types of cookies that you may receive when browsing a website, which can be classified based on their purpose. These include techinical cookies, browsing / session cookies, and function cookies (all of which usually don’t require your consent,) analytics cookies and profiling cookies (which usually require your consent).
Cookies can also be divided into first-party cookies and third-party cookies, depending on whether they are sent to your computer and managed by the owner of the website, or by someone else.
– What cookies do we use?
Our website uses the following types of cookies:
|Technical Name||Cookie type, function and purpose||Duration|
Determines if the user has previously viewed interstitial / pop-up content on the current page.
|Google (Google Analytics, DoubleClick)||https://policies.google.com/technologies/ads
Our website uses Google Analytics. Analytics is a tool developed by Google that collects information allowing for your use of the site to be evaluated, analyzed and is meant to improve your browsing experience. You can read more about how to opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
– How can I change my cookie settings?
You can block or delete the cookies used on our website via your browser options. Your cookie preferences will be reset if use change the browser you use to access our website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:
ATTENTION! If you block or delete the technical and/or function cookies used on our website, it may not be possible to browse our website and/or some of the functions of our website may not be available. In this case, you may need to manually enter your information and preferences each time you visit our website.
3. Purposes of the processing
Why does Curvature process my personal data?
We use your personal data that we collect through the website for the following reasons:
- We need your personal data to verify your identity, so that you can access different restricted areas of our site (such as the Customer Portals), and so that we can help you in case you lose or forget your login/password details. When you request a quote from us or send us a message, we will use the personal data you provide in order to address your request and respond to you. In general, whenever you ask us to provide any services to you through the website, we will use the personal data you share with us to address your requests.
- We use your personal data in this manner because we need to in order to properly provide you with the website’s functionalities, or to address a request you make to us. In these cases, you don’t need to provide you with our personal data, but if you decide not to, we won’t be able to provide you with our services.
- We may use personal data you provide to us to send you offers and promotions related to Curvature’s services, as well as surveys, by e-mail or SMS.
- We use your personal data in this manner because we have assessed that we have a legitimate interest in promoting our services to our existing and potential customer base You are not required to allow us to use your personal data for these purposes and will not suffer any consequences if you decide not to (though you will not be able to receive further marketing communications from us).
- We can collect information on the preferences you select and choices you make on our website, through the use of profiling cookies (see Section 2-E above), which we may use to automatically generate a profile of you as a website user. This profile will then be used to show you information about other websites or services which we believe you may be interested in, including advertisements. In order to ensure that your personal data is handled fairly, and to avoid any unwanted biases, we regularly test the algorithms used to generate these profiles.
- We only use your personal data to create a profile of you if you consent to this, by accepting the use of profiling cookies on our website (through the pop-up banner you have been shown, at the top of our website). You are not required to provide us with your consent for this purpose (but you won’t be able to benefit from personalisation of your site experience). You can withdraw your consent for profiling cookies at any time (see Section 6 for more information.)
- When we collect your personal data, we may be required to store it for a certain amount of time, or report it to official authorities, because we are legally required to do so. This may be the case, for example, where we are required to retain or report your data to official authorities in order to meet tax, customs or other legal obligations.
- We only handle your data in this manner where this is strictly necessary in order to comply without legal obligations.
- We can collect information on the manner in which you interact with our website, such as the pages you visit and how much time you spend on each page, through the use of analytics cookies (see Section 2-E above). We will use the information collected to improve our website, as well as the services we offer on the website.
- We only use your personal data for these purposes if you consent to this, by accepting the use of analytics cookies on our website (through the pop-up banner you have been shown, at the top of our website).
Prevention of Misuse/Fruad
- We can analyse the browsing data and other information collected on how you and others use our website, in order to ensure the security of our website, as well as detect and prevent any misuse of our website.
- We use your personal data in this manner because we have assessed that we have a legitimate interest in ensuring the security of our website and preventing the use of our website for potentially criminal purposes.
4. Recipients of personal data
Your Personal Data may be shared with other following people/entities (Recipients):
- People, companies or firms that provide us with advice and consultancy concerning accounting, administrative, legal, tax, financial and debt collection matters in connection to our services;
- Entities that help us provide our services such as hosting providers and email platform providers;
- People we authorize to carry out technical maintenance (such as maintenance of network equipment and electronic communications networks);
- People we authorize to process personal data in order to perform activities that are related to the provision of our services, like our employees. These people are under legally binding confidentiality obligations.
- Other companies within the Curvature Group;
- Public entities, bodies or authorities with whom we share personal data, when strictly required by law (such as local tax, customs or law enforcement authorities).
5. Transfers of personal data
Since we are a global company with presence in many countries, your personal data may be transferred to recipients in multiple countries. We genuinely care about your privacy and for that reason we have implemented appropriate safeguards to protect your information when it is transferred. Some of these safeguards include adequacy decisions of the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions that are considered adequate to the relative transfer of data.
6. Retention of personal data
Retention for Service Provision Purposes
We only keep the personal data that we process for Service Provision for as long as is strictly necessary. In some cases, however, we may need to store such personal data for a longer period of time if doing so is necessary to protect ourselves from liabilities related to the provision of services (in this case, under restricted conditions of use).
Retention for Marketing Purposes
We will keep your data that we process for marketing until you unsubscribe or opt-out of such communications. If you decide to opt-out, we will not use your data for marketing purposes anymore; however, we may need to keep it for longer if we have an existing business relationship with you, or in order to protect ourselves from liability (in this case, under restricted conditions of use).
Retention for Profiling Purposes
We will keep your data that we process for profiling purposes from the moment you give us your consent until the moment you withdraw such consent. Once you withdraw your consent, we will no longer use such data for profiling purposes, but may need to keep it for longer in order to protect ourselves from liability (in this case, under restricted conditions of use).
Retention for Analytical and Misuse/Fraud
We will keep data we process for as long as necessary to fulfil the proposes for which we collected it unless you object to the processing of your data for these purposes (see Section 8 for instructions on how to object).
7. Data subjects’ (your) rights
What are my rights, regarding my personal data?
As a data subject, you can exercise the following rights at any time:
- Access your personal data that we are processing (or receive a copy of those personal data) and obtain information about such processing;
- Correct or modify your personal data that we are processing when it is inaccurate or incomplete;
- Request that we erase your personal data that we are processing when you feel that the processing is unnecessary or unlawful;
- Request restriction of the processing of your personal data when you feel that the personal data we have on you is inaccurate, unnecessary or has been unlawfully processed, or when you have previously objected to its processing;
- Exercise your right to portability: you can request a copy of the personal data you provided to us, in a structured, commonly used and machine-readable format, and you can request that those personal data be transmitted to another data controller;
- Object to our processing of your Personal Data, based on relevant grounds that are related to you and your situation, which you believe should prevent us from processing your personal Data; or
- Withdraw your consent to processing (for Analytics or Profiling).
You can exercise any of the rights mentioned above by sending a written request to: [email protected]
If you have created a registered user profile on our website, please note that most of the personal information you provide to Curvature can be changed at any time, including your e-mail preferences, by accessing your user profile.
You can also object to the processing of your personal data for Marketing, without needing to provide any justification for this, by selecting the appropriate link included at the bottom of marketing e-mail messages. You can also withdraw your consent for Profiling or Analytics by blocking or opting-out of the profiling/analytics cookies used on our website (see “How can I change my cookie settings?”).
As a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of personal data, if you believe that the processing of your personal data carried out through our website is unlawful.
8. Additional Information for California Residents
You have certain consumer privacy rights under the California Consumer Privacy Act (CCPA) if you reside in California. The CCPA requires that we provide you with the following additional information about how we use and disclose your personal data.
Personal Data. We collect certain information about individuals that is considered “personal information” under the CCPA. Some of that information is described above in Section 2 (Personal data processed). We may also collect the following types of personal data:
- Identifiers: contact details, identification information.
- Personal information: contact details, identification information.
Commercial information: information required for the purchase, sale, provision and use of our products and services.
- Internet or other electronic network activity information: login credentials, browsing history, search history and digital activity information.
- Geolocation data: Device location.
- Inferences drawn from other personal information: Certain inferences concerning an individual’s preferences.
- Other personal information: CCTV footage, professional and employment related information, information contained in resumes or CVs submitted to us and information made publicly available on professional social networks.
Sources. We may collect personal data from you and from third parties. The categories of third parties from whom we may collect personal data include the following:
- Partners and resellers
- Public authorities
- Third party applications (such as social networks)
- Advertising networks
- Other companies or organizations (such as market research firms and data aggregators).
Purposes. We collect your personal data for the purposes described in Section 3 above (Purposes of the processing). We also collect and share your personal data in order to allow us to provide our products and services to you and/or your employer.
Sale of Personal Data. We do not sell your personal data.
CCPA Consumer Rights.
Right to Access. You have the right to request that we disclose the categories of personal data collected about you in the preceding twelve-month period. We must also provide you with a summary of the purposes for which the categories of personal data were collected. Once you submit an access request, you may also separately request a portable copy of the specific pieces of personal data that Curvature has collected about you (subject to heightened verification). We will disclose the applicable information specified above to you upon receipt of your verifiable consumer request.
Right to Deletion. You have the right to request that we delete your personal data subject to the various exceptions provided in the CCPA.
Submitting a Verifiable Consumer Request. In order to protect your information, we can only honor access or deletion requests upon receipt of a verifiable consumer request. Your request must provide information that enables us to verify your identity for us to respond. You agree to respond to any reasonable requests from us for additional information to enable us to verify your identity in connection with your access or deletion requests. You may submit a verifiable consumer request by either of the following methods:
- Sending us an email at [email protected]
- Contacting us by telephone at 877.559.7769.
Upon receiving a request, we will attempt to verify your identity and will respond within no more than forty-five days as required by the CCPA.
Right to Nondiscrimination. We will not discriminate against you because you elect to exercise any of your rights under the CCPA including in any of the following ways:
- Denying goods or services to you.
- Charging you different prices or rates for goods or services.
- Providing a different level or quality of goods or services to you.
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.