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This policy regarding the collection and processing of personal data (the “Privacy Policy”) describes how Columbus Global UK Ltd, Pure Offices Lake View Drive, Annesley Nottingham NG15 0DT, Great Britain, Reg.no 02890010. (“we”, “us” “our”, or “Columbus”) process personal data. Through the Privacy Policy, we fulfil our duty to inform you as a data subject regarding our processing of your personal data in accordance with article 13 and 14 of Regulation (EU) 2016/679 (the “GDPR”).

Collection and processing of Personal Data

We process personal data in several different instances.

When you visit and use our website, we process personal data about you, e.g. by using cookies. This data is used to improve our website, including to collect statistics about the usage and effectiveness of our website, and the user experience, to perform costumer support and target advertising, to personalize your experience and to tailor our interactions with you.

We also process your personal data when you use functions on our website as signing up for one of our newsletters or webinars, send us data or request information about one or more of our services. If you request something from Columbus (e.g. a product or service, a call back, or specific marketing materials), we will use the data you provide to fulfil your request. In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.

Finally, we process personal data when you or your organization enter into agreement with us regarding delivery of our services - hereunder products and software. We will use this personal data to fulfill our agreement with your organization. We may also contact you as part of our customer satisfaction surveys or for market research purposes.

Additionally, Columbus may make available mobile applications for download from various mobile application marketplaces. We may also provide social computing tools directly or indirectly to enable online sharing and collaboration among members who have registered to use them. These may include forums, wikis, blogs and other social media platforms.

The personal data that we collect, either directly or indirectly, may be combined to help us improve its overall accuracy and completeness and to help us better tailor our interactions with you. The personal data you provide to Columbus may also be used for direct marketing purposes. Before we do so, however, we will ensure that either we have obtained your specific consent to have your personal data used in this way or that it is necessary for the purposes of the basis legitimate interest pursued by us in securing delivery of our products and services.

The personal data we process will normally be of non-sensitive nature. The types of personal data which we process include e.g. your user name, password, email address, first name, surname, job position, company name and phone number. In addition, some of our software products include technologies that allow us to collect certain information about product use. We may also use such technologies to determine whether you have opened an e-mail or clicked on a link contained in an e-mail.

Please see the table below for a more detailed description of how we process your personal data:

Data subjects

Personal data (non-sensitive)

Purpose

Legal basis

All website visitors.

Statistics of website use, e.g. IP addresses, operating systems, browser types, geo-location, entry/exit webpages, time stamp and clickstream data.

To make available and improve our website, to customize its content to visitors, to perform customer support and to analyze website trends.

To create user profiles to provide tailored promotions and marketing offers based on e.g. location, behavior or other tracking, e.g. via cookies.

Our legitimate interest in making our website available and customizing it to visitors etc., cf. article 6(1)(f) of the GDPR.

Consent to place cookies on the terminal equipment the visitors, cf. Executive Order no. 1148 of 9 December 2011 on Information and Consent Required in Case of Storing or Accessing Information in End-User Terminal Equipment.

Persons using or purchasing our services and products, including signing up to webinars, newsletters, etc

Usernames, passwords, email addresses, names, job positions, company names, phone numbers, information on whether e-mails have been opened, information on whether links provided in e-mails have been clicked, information on service use.

To enable data subjects to use services provided by us, including provision of e-mails, newsletters, webinars, etc.

To contact data subjects regarding satisfaction surveys or market research.

To directly market our services to data subjects.

Our legitimate interest in enabling data subjects to use services provided by us and to contact data subjects, cf. article 6(1)(f) of the GDPR, and in some cases, our performance of contract with the data subjects, cf. article 6(1)(b) of the GDPR.

Consent to receive direct marketing, cf. article 6(1)(f) of the GDPR and section 10(1) of the Danish Marketing Practices Act.

Persons requesting information on our services or otherwise contacting us.

Email addresses, names, phone numbers, information on whether e-mails have been opened, information on whether links provided in e-mails have been clicked.

To process and respond to requests and queries from data subjects, including to contact data subjects regarding satisfaction surveys or market research.

To directly market our services to data subjects.

Our legitimate interest in processing and responding to requests and queries from data subjects and contacting them, cf. article 6(1)(f) of the GDPR.

Consent to receive direct marketing, cf. article 6(1)(f) of the GDPR and section 10(1) of the Danish Marketing Practices Act.

Employees (contact persons) of our business partners.

Email addresses, names, job positions, company names, phone numbers, information on whether links provided in e-mails have been clicked, information on product use.

To fulfill the contract with the employer of the data subjects, to contact the data subjects etc., including to contact data subjects regarding satisfaction surveys or market research.

To directly market our services to data subjects.

Our legitimate interest in contacting the contacts in order to fulfill the contract with the organization, cf. article 6(1)(f) of the GDPR.

Consent to receive direct marketing, cf. article 6(1)(f) of the GDPR and section 10(1) of the Danish Marketing Practices Act.

Users of our mobile applications and social computing tools (users (subject to any supplemental privacy policies issued regarding such).

User names, passwords, email addresses, names, job positions, company names, phone numbers, information on product use.

To enable online sharing and collaboration among members who have registered to use such services.

Our legitimate interest in making the functionalities of our services available to users, cf. article 6(1)(f) of the GDPR.

 

If you tell us that you do not want us to use your data to make further contact with you we will respect your wishes, in accordance with the section "Your Rights as a Data Subject” below.

Cookie:

Please find more information on our processing of cookies in our Cookie Policy: https://www.columbusglobal.com/en/cookie-policy

Sources of Personal Data

We collect the above personal data from you or your terminal equipment. From time to time, we may also collect personal data that pertains to you through other sources, such as our suppliers or your organization.

Insofar as the processed personal data is provided by you, it is voluntary for you to provide the personal data. However, if you do not provide the personal data, we may not be able to provide our services to you. Personal data provided by your employer is necessary for the performance of our contract with your employer.

Disclosure

To help us provide our services, we may share the personal data with others, for instance our business partners, financial institutions, shipping companies or postal or government authorities, such as customs authorities, involved in the fulfilment of your request.

We also share your personal data with our data processors, e.g. in relation to hosting of IT services, backup, support and web development. It is our practice to require such data processors to handle personal data in a manner consistent with our policies.

Additionally, we may disclose your personal as required by law and/or when we reasonably believe that disclosure is necessary in order to protect the rights or property of Columbus, our business partners, suppliers, customers, or others and/or when disclosure is necessary to comply with a judicial proceeding, court order, or legal process served on our website.

Such parties can be located inside or outside the EU/EEA.

Group Transfers and other International Transfers

Columbus is part of a global organization with business processes, management structures and technical systems that cross borders. As such, we may share personal data about you within Columbus and transfer it to countries in the world where we do business in connection with the uses identified above and in accordance with this Privacy Policy. Our Privacy Policy and our practices are designed to provide a globally consistent level of protection for personal data all over the world.

We may transfer your personal data to so-called “third-countries” outside the EU/EEA, including the United States, Switzerland, India and Russia. Such transfers are based on either the standard contractual clauses of the European Commission https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en adequacy decisions from the European Commission https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en the recipients’ self-certifications under the EU-U.S. and/or Swiss-U.S. Privacy Shield Frameworks https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_en or another applicable legal basis for such transfer.

Please contact us (see 'Contact Us' section at the end of the page) if you have questions on our use of data processors, engagement of other data controllers or transfer to third countries, including any requests of documentation of the necessary levels of data protection. Find our contact information at the end of this Privacy Policy.

Your Rights as a Data Subject

You have a number of rights regarding personal data relating to you. Columbus is committed to helping you with exercising your rights as an individual. To do so, please contact us (see 'Contact Us' section at the end of the page). Your rights include:

  1. to know what personal data we process about you, for what purposes we process it, whether we disclose the data to others, along with other information on the processing;
  2. to rectify your personal data if it is incorrect;
  3. in certain cases, to have some or all of your personal data deleted before the end of our retention period;
  4. in certain cases, to have the processing of your personal data restricted to storage. Insofar as you can enforce this right, we may only process personal data (except from storage) with your consent, or to establish, exercise or defend a legal claim, or to protect a person or substantial public interests;
  5. in certain cases, to receive or transmit to third parties the personal data which you have provided to us in a structured, commonly used and machine-readable format;
  6. in certain cases and on grounds relating to your particular situation, to object at any time to the processing of your personal data. You may also object to our processing of your personal data for direct marketing purposes;
  7. to withdraw any consent that you have given to the processing of your personal data, without affecting the lawfulness of processing based on consent before its withdrawal; or
  8. to lodge a complaint with a supervisory authority.

Read about our Data Protection Measures here

Retention

As a main rule, we will retain the personal data you provide to us for 24 months or for as long as the personal data is required to fulfil your request. In some cases, we may process personal data for longer than this period, e.g. when we are allowed or required to do otherwise by law or in order to establish, exercise or defend a legal claim.

If you wish to request that we no longer use your personal data, please contact us (see 'Contact Us' section at the end of the page). We reserve the right to retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, etc.

Complaints

You have the right to make a complaint at any time to the competent Supervisory Authority in our jurisdiction. In Great Britain, the competent Supervisory Authority is The Information Commissioner (www.ico.org.uk).

However, we would appreciate the chance to deal with your concerns before you approach the competent Supervisory Authority in our jurisdiction, so please contact us (see 'Contact Us' section at the end of the page) in the first instance.

Contact Us

If you have a question about this Privacy Policy or our handling of your personal data, or if you no longer wish to receive marketing e-mails from Columbus, please Contact Us or follow the unsubscribe instructions included in each marketing email.

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