Federos provides a number of web sites in order to facilitate interaction between ourselves and our customers, partners and suppliers. We use these web sites for purposes such as (without limitation) providing you with information about Federos’ products and services, providing support for customers with active maintenance agreements, distributing software, providing online training, and providing information of potential interest to you (collectively, “Online Services”). The Online Services include (without limitation) our website (www.federos.com), and other sites linked to our website, some of which are operated by Federos and others which are not. In order to provide an appropriate, secure environment to transact business with you we must ensure we know who you are, and what organization you are associated with. To do that, we need to collect and process some personal information from you, such as your email address, name and the company you work for.
Certain countries (“Designated Countries”) have enacted legislation mandating disclosure of how we collect, process and share personal information you provide us. Designated Countries include members of the European Union (EU), European Economic Area (EEA), Switzerland and the United Kingdom. Federos has instituted policies and security measures intended to ensure that your personal information is handled in a safe, responsible manner that is in compliance with this legislation. For the purposes of GDPR compliance the data protection supervisory authority is the ICO (Information Commissioners Office – https://ico.org.uk/).
INFORMATION WE COLLECT
INFORMATION YOU PROVIDE TO US
In order to provide secure access to appropriate information relevant to you or your organization, we will ask you to provide some personal information from you as part of the registration process. Personal information collected for this purpose includes your:
- Job Title
- Company or Organization
- Mailing, Billing and Shipping addresses
- Work email address
- Work phone number
INFORMATION WE OBTAIN FROM OTHER SOURCES
To help us provide an optimal user experience when you use our Online Services, we may obtain information from other sources. Examples include (without limitation):
- Web pages your Internet browser visits when accessing the Online Services
- Aggregate data, such as the number of hits per week, per web page
- Information stored in your browser from prior visits to the Online Services (“Cookies”)
- The Internet Protocol (IP) address used when you access the Online Services
COOKIES AND LOG FILES
As is true of most websites, we gather certain information automatically. This information includes browser type, internet service provider, referring/exit pages, operating system, date/time stamp and click stream data.
We use this information, which does not identify individual users, to analyze trends, administer the site, track users’ movements around the site and gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.
HOW WE USE YOUR INFORMATION
We use your data in a variety of ways, intended to enable or improve your experience when interacting with Federos and Federos’ Online Services. In this section we will describe how we use your information.
ESTABLISHING YOUR IDENTITY
In order to use many of the Online Services, you must register your identity with Federos. This is needed in order to ensure the information you or your organization has shared with Federos can be protected from unauthorized disclosure or compromise by someone other than you, your organization or Federos. We establish your identity and confirm your affiliation with your organization using your work email address. When using the Online Services, you will be required to log in using your work email address as a user id and a password that only you know. In order to protect your information and that of your organization, we request that you do not share your user id and password with anyone else. As part of the registration process we will send a confirmation to your work email address, so that we can verify the person registering as you is, in fact, you. We use the domain in the work email address you provide to associate you with your company or organization. For this reason, we do not accept email addresses from non-company affiliated domains (such as gmail.com, Hotmail.com, icloud.com and so on).
IMPROVING YOUR ONLINE EXPERIENCE
In order to provide you with a comfortable, personal user experience when using the Online Services, we ask you to provide your first and last name as part of the registration process. This allows Federos to work with you at a personal level. At certain points in the Online Services we may request your job title, so that we can provide you with information appropriate to your role in your company or organization. We may monitor posts you make in our customer or partner forums, to verify compliance with forum guidelines, resolve complaints from other forum members, or remove posts in response to your or other community members reasonable requests.
ENABLING US TO COMMUNICATION WITH YOU
We may ask for a telephone number where we can call you, such as when completing a form asking us to contact you by phone. We may also ask for a mailing address, shipping address, or billing address so we can exchange business correspondence with you. We use your email address to provide you with updates on customer support cases and encourage you to provide information to us by replying to such emails. Doing so alleviates the requirement to log in to a support portal when interacting with our support team. We may send you surveys about your experiences working with Federos, such as satisfaction with our handling of a support case or professional services engagement.
ADVERTISING AND MARKETING
We may use your work email address to share information with you about our products and services or other information you have either requested or we believe would be of relevance and interest to you. We collect information about you from our Online Services when you visit them, in order that we may determine the effectiveness of our content, marketing and advertising campaigns, using technologies such as beacons, search strings, pages visited and other sources of both personal and anonymized (aggregated) data.
In order to work with you on cases you have opened in our customer support system, we may request information from you about your implementation of Federos’ products. This information may include information you enter into the support system, images (such as screen shots) or files (such as log files or database extracts). If you take advantage of our support system’s ability to provide you updates via email and capture your response to that email in the customer support system, any information contained in that email will stored in the customer support system. This includes data like your email address, the names and email addresses of anyone you copy on the response, the contents of your email signature block (if present), any attachments to the email and any text you enter in the email. Some or all of this data may contain personal identifying information of you or others.
SECURITY AND COMPLIANCE
We may use information you have provided or that we have gathered from other sources if we believe it is necessary to investigate or remediate violations of our policies, agreements or contracts or the laws of any country. We may use either personally identifiable information or aggregated information in order to demonstrate compliance with relevant statutes, or to comply with audits of our internal processes or business information.
HOW WE SHARE INFORMATION ABOUT YOU
Federos’ policy regarding sharing of information is that we do not disclose, reveal or share any personally identifiable information describing you during the normal course of business to anyone other than you, your company or organization, or our staff. Further, any such disclosure is limited to those individuals with a need to access that information in order to meet our contractual and legal requirements. For instance, our staff working in the customer support organization by necessity need access to information you have provided in the context of a case we are working on together. Federos does not sell, trade, exhibit or share information you have provided with us with any third party.
There are limited exceptions to this policy, which are outlined below.
SERVICES PROVIDED BY OTHERS
In certain cases, some of the Online Services we provide to you use systems not owned by Federos. For instance, the identity portal stores information you provide such as your work email address, first and last name and company or organization affiliation in a third-party Identity and Access Management (IAM) platform. Information you provide in the context of a customer support case is stored in a third-party ticketing system. In all cases Federos has verified that the data stored in these “hosted systems” is encrypted both in transit and at rest and is not visible in clear text form to the vendors supplying the services on these platforms.
SUSPECTED OR ACTUAL CRIMINAL ACTIVITY
Federos may be required to disclose information that you have provided or that we have collected about you, your company or organization if compelled to do so by a competent jurisdiction through legal instruments such as a court order or subpoena if we have a good faith belief that such a disclosure is reasonably necessary to investigate, prevent or take action on suspected or actual illegal activities or to assist governmental agencies.
Federos may choose to disclose information that you have provided or that we have collected about you, your company or organization if necessary to enforce agreements to which we are both parties, to investigate or provide a defense against third party claims or allegations, to protect the security and integrity of the data in our systems or to protect the rights or safety of our employees, customers and partners.
AGGREGATED OR ANONYMIZED DATA
Federos may share information that does not personally identify you, your company or organization with a third party in order to carry out a reasonable business process, such as to satisfy an audit, demonstrate compliance with internal policies, or optimize the performance of our Online Services.
CHANGE OF CONTROL
Federos may share information (whether or not it contains personally identifiable information) with a third party governed by appropriate non-disclosure agreements to assist in preparing for or executing a sale or change of ownership of Federos. Any entity purchasing Federos will have the right to continue to use this information subject to the terms of this Privacy Statement unless you agree otherwise.
YOUR RIGHTS, CHOICES AND OBLIGATIONS
This privacy statement provides certain rights and obligations on you and provides you with choices as to how we collect, store and use data you provide.
Federos will retain the information you provide indefinitely, unless you request otherwise, to be used in accordance with this Privacy Statement to provide you, your company or organization with services.
YOUR RIGHTS TO ACCESS AND CONTROL YOUR PERSONAL DATA
Federos provides you with choices when it comes to how you would like us to manage your personal data. With respect to personal data we have about you, you have the right to:
- Have us delete your personal data;
- Change or correct your personal data;
- Limit or restrict our use of your personal data;
- Obtain a copy of your personal data
To exercise these rights, please send an email to DPO@federos.com describing your wish to exercise one or more of these rights.
You should be aware that the exercise in some of these rights may limit the services Federos is able to provide to you. For instance, if we delete your personal data (at your request) inclusive of your work email address, you will no longer be able to access the Online Services.
OTHER IMPORTANT INFORMATION
CHANGES TO THIS PRIVACY STATEMENT