TYPES OF INFORMATION COLLECTEDWe collect the following information:
- identification, including name and user identification, Internet Protocol (IP) address, other metadata contained in communications you send to us;
- contact information, including email address, physical address, telephone number, fax number;
- information about a product, such as product name, product key, order number, operating system, for example in a request for technical support;
- messages you send to us, for example, a product inquiry;
- information necessary to verify eligibility to use a Website service or to facilitate dealings or transactions, such as your company information, job title, investor type;
- information necessary to apply for a job, such as work history and education history;
- any other information you voluntarily provide to the Company or Company personnel through one of our Websites; and
SOURCES FOR COLLECTING THE INFORMATIONWe collect such information from the following categories of sources:
- Directly from you. For example, when you contact or request information from the Company including via our Websites, when you create a user account, or when you apply for a job.
- Third Parties, including Service Providers. For example, your internet service provider, service providers that you authorize to provide information about you; and/or service providers that the Company uses and other third parties that the Company chooses to collaborate or work with.
- Using cookies and automatic collection methods. The Company and its service providers may collect information from the computer, tablet, phone, or other device that you use to access our Websites, or that you use to open an email from the Company. The Company does not respond to “do not track signals.”
PURPOSES FOR COLLECTING THE INFORMATIONWe collect, use, retain, and disclose your personal information for the purposes described below. We reserve the right to update or amend this Policy at any time, without notice, to update, add, or remove the purposes for which the Company uses personal information:
- To provide you with our services, such as to: use the Websites; process, maintain and service your account(s);
- Register an account, manage user relationship, and communicate with you;
- Measure user engagement with the Websites;
- Handle and record consumer rights requests, including opt-ins and opt-outs;
- Monitor, protect and improve the Company’s security assets and resources, including devices, systems, customer data, intellectual property, infrastructure, and network, conduct investigations and respond to or pursue legal actions or complaints;
- Administer our employment, contracting, business, or other relationship with you or on your behalf; and
- Comply with laws, regulatory requirements and to respond to lawful requests, court orders and legal processes.
SHARING OF THE INFORMATIONWe disclose the above categories of personal information to the following categories of third parties for a business purpose, in some cases as directed by you. For example, in the preceding 12 months, the Company has disclosed your information to:
- Corporate Affiliates. For example, our corporate affiliates may share business processes and common data systems.
- Third parties and service providers that provide products or services to us. For example, companies that help us support our Websites, or that provide services to you. The Company may use third parties or service providers to help with auditing interactions and transactions with you, addressing security, fixing errors, helping us with advertising or marketing, maintaining accounts and providing customer service, helping with our internal research, and verifying service quality or safety.
- Government authorities. For example, tax authorities, safety and health authorities, law enforcement, and the like in accordance with applicable local laws and regulations.
LOCATION OF DATAThe personal information collected through the Websites may be downloaded to servers located in the United States and other countries maintained by service providers under contract with the Company.
MINORSOur Websites are not intended for children, and we do not knowingly collect personal information from anyone we know to be under 16.
CONTACTIf you have any questions or requests regarding the Company’s collection, use, and sharing of your data, please contact firstname.lastname@example.org.
REGION-SPECIFIC SUPPLEMENTAL NOTICESWhile the above disclosure applies to all users, each of the following sections is ONLY applicable to users in a specific geographic region. As such, they may or may not be applicable to you. To the extent that any region-specific section is applicable to you, please read the relevant section as a supplement to the privacy disclosures above.
This section applies solely to residents of the State of California (“consumers” or “you”). Any terms defined in the California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”) have the same meaning when used in this notice and policy. This notice and policy do not reflect our collection, use, or disclosure of California residents’ personal information, or data subject rights, where an exception under the CCPA applies.
- Right to know about personal information collected and disclosed, and to request deletion of personal information
- You have the right to request that we disclose what personal information we collect, use, or disclose about you specifically (“right to know”) and to request the deletion of personal information. To submit a request to exercise these rights, please submit an email request to email@example.com.
- We may ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
The Company does not sell, and in the preceding 12 months did not sell, California residents’ personal information.
The Company does not have actual knowledge that it sells the personal information of minors under 16 years of age.
- Personal information handling practices
|Corresponding reference to category of personal information under CCPA definition of personal information||Personal information collected|
|A. Identifiers.||First and last name, address, telephone number, e-mail address, username, order information, IP address.|
|B. Personal information categories listed in the California Customer Records Act (Cal. Civ. Code § 1798.80(e)).||First and last name, address, telephone number, work and education history from job applicants.|
|C. Characteristics of protected classifications under California or federal law.||Job applicants only – citizenship or immigration status for compliance with immigration or export control law; you may also have options to provide racial, ethnic origin, gender disability, veteran status for the Company’s compliance with law and diversity monitoring|
|D. Commercial information.||Viewing history of the Company’s Websites|
|F. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web website, application, or advertisement.||Times of visit, time spent on website, network location and IP address, operating system, date and time stamps of actions|
|G. Geolocation data.||Region or country|
|H. Audio, electronic, visual, thermal, olfactory, or similar information.||Communications such as messages you send us through our websites, voicemail you leave us, recording of customer or technical support calls|
|I. Professional or Employment related information.||Job applicants only – work history|
|J. Education information.||Job applicants only – education history|
- Right to non-discrimination for the exercise of CCPA rights
- Authorized agent
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California and the agent provides proof that you gave the agent signed permission to submit the request; and
- You directly confirm with the Company that you provided the authorized agent with permission to submit the request.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
B) EUROPEAN ECONOMIC AREA, UNITED KINGDOM AND SWITZERLAND
Identity of Controller
Silfex Inc., 950 South Franklin Street Eaton, OH 45320, U.S.A., is the data controller. Please submit requests by email to firstname.lastname@example.org.
Legal Basis for Processing and Consequences of not Providing Personal Data
We process your personal data on several different legal bases, as follows:
- Based on necessity to perform contracts with you - we need to process your personal data to answer questions and requests from you including when you complete forms requesting information or signing up for emails.
- Based on legitimate interests - where our legitimate interests are security and safety; to detect and prevent fraud; to protect and defend the rights or property of others, or our own rights and interests.
- Based on compliance with legal obligations - we may need to process your personal data to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders, and legal process.
- Based on your consent if you opt in to our mailing or call lists and if you accept the placement of not strictly necessary cookies. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
- If you provide your personal data when using our online employment application service, the legal basis for our processing of your personal data is your consent. You are not obliged to provide personal data in this context, but we will not be able to evaluate your candidacy unless we receive sufficient personal data to fully consider your application. If you rescind your application or if we decide to no longer consider your application, we will delete the personal data in your application within one year of such time.
- If you provide your personal data in connection with a request to receive investor information, the legal basis for our processing of your personal data is your consent. You are not obliged to provide personal data in this context, but we will not be able to provide you with investor information unless we receive your personal data.
Silfex Inc. and some of our affiliates and service providers are based in the United States, a country with respect to which the European Commission has not issued an adequacy decision. The transfer of your personal data to the United States is necessary for us to provide our Websites because Silfex Inc. is located in the United States. If you do not wish to have your personal data transferred to the United States, do not initiate such transfers by using or submitting information through our Websites.
Period of Data Storage
The Company will process your personal data only for as long as necessary for the purposes for which it was collected, to provide you the Websites, for legitimate purposes, in accordance with contract, and where required or allowed under law. We retain online account related personal data as long as your account is active and if you have opted in to receive marketing communications as long as your opt in is active. When we no longer need to retain your personal data, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your personal data to comply with legal or regulatory obligations, or to preserve evidence within the statutes of limitation.
Data Subject Rights
You may have a right to request from the Company access to, rectification, or erasure of personal data, or restriction of processing concerning the data subject, or to object to processing, as well as the right to data portability; you can exercise such rights by emailing email@example.com. Please note that these rights might be limited under applicable data protection law.
If you have provided your consent for our data processing, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. If you withdraw consent, we may no longer be able to provide certain services to you. You may also have the right to lodge a complaint with a supervisory authority.