Effective date: 1 January 2020
- Information we collect
S7clear collects personal data in the course of its business activities, including in connection with some client services. We also collect personal data on certain areas of the Sites when you register for or apply for jobs through the S7clear Recruitment Portal, create a user profile, register for S7clear newsletters and alerts, participate in our alumni activities through our Alumni Center Website, sign up for conferences and events, and/or participate in public user posting areas (such as bulletin boards, discussion forums and surveys). The personal data collected varies and may include information that you provide, such as your name, mailing address, e-mail address, telephone number, fax number, and background information required to apply for a job.
We may also automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected may be associated with a unique identifier as well as with any other personal data you have provided.
S7clear may also collect personal data about you from third parties, such as data brokers or aggregators, in the course of its business activities including in connection with some client services. This includes demographic, professional and other information that is publicly available online, including information you choose to make public through social media platforms and other public online forums. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities (e.g., analysis of recruiting practices across an industry, detecting fraud patterns in connection with financial transactions, foot traffic in retail environments). We will always seek to confirm that the third party has provided transparent information about its use of this data, including its disclosure to third parties like S7clear, in compliance with applicable law.
- Use of information
Our Sites do not track you by collecting personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.
- Use of information collected via mobile devices
In connection with our mobile applications, S7clear may use third party service providers to analyze user activity to fix errors, monitor usage, and improve the performance of the mobile applications. For example, S7clear receives reports on some of our mobile applications’ aggregate usage and browsing patterns, including information about the type of device used, articles accessed, and other events occurring within our apps. S7clear also receives reports on certain errors occurring within mobile applications.
In addition, our S7clear Insights app offers a personalized list of recommendations (called “Insights for you”) directing you to S7clear content that we think you will find interesting. Recommendations are based solely on what you have viewed in the Insights app. A unique user identifier that is generated by the app helps personalize your app experience and tracks the articles that you read in the app. We do not share your viewing history or trends through the Insights app with other users or any external third parties (i.e., persons or entities that are not affiliates or third party service providers of S7clear).
- The legal basis by which we process your personal data
Our processing of your personal data for the purposes mentioned above is based:
in part, on our legitimate interests in promoting and protecting S7clear, building and maintaining relationships. recruitment, and providing our services;
in part, on your consent, for example if you create a user profile, or register for our newsletters or alerts, or for business purposes that support web operations such as understanding and enhancing the quality of your experience on our web-sites;
in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.
Disclosure of personal data: data recipients and international data transfers
Personal data collected in the course of S7clear business activities, including in connection with some client services, as well as on the Sites may be transferred from time to time to S7clear subsidiaries and affiliates and their personnel across our global organization, as well as to our third party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Sites may be viewed and hosted by S7clear and our third party service providers anywhere in the world. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by S7clear subsidiaries, affiliates and third party service providers, including the transfer of your personal data to countries other than the one in which you reside. If you would like more information about these legal mechanisms, which may include the EU’s Standard Contractual Clauses, please contact us at the address below. By using any of the Sites and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information.
We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing recruitment materials, administering surveys or contests, or communicating with you.
In addition, we may disclose information about you:
If we are required to do so by law or legal process;
To law enforcement authorities or other government officials;
When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
If disclosure is necessary to protect the vital interests of a person;
To protect our property, services and legal rights;
To prevent fraud against S7clear, our subsidiaries, affiliates and/or business partners;
To support auditing, compliance, and corporate governance functions; or
To comply with any and all applicable laws.
In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
- User forums
You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. S7clear is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.
- Link to third party sites
- Social Networking
The Sites may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube, with S7clear. The Sites also may allow you to log in to a S7clear account using certain social network account credentials.
If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.
S7clear has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized S7clear personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions however, S7clear cannot guarantee that unauthorized persons will not obtain access to your personal data.
- Data retention
S7clear retains personal data, as necessary, for the duration of the relevant business relationship.
The Sites are not designed for or directed at children 16 years of age or younger, and S7clear does not intentionally collect or maintain personal data about anyone under this age.
S7clear Recruitment portal/S7clear Recruiting Program/Alumni Center website
Through the S7clear Recruitment portal, you can apply for positions with S7clear or sign up for a S7clear Recruiting Program where you can be notified of any potential job openings or other similar opportunities that might be of interest. The Recruitment Privacy Notice describes more in detail how S7clear and our subsidiaries and affiliates handle and protect the personal data that we collect in connection with the recruitment process.
If you are a former S7clear employee, you may be eligible to join our Alumni program and have access to the Alumni Center website. The Alumni Center website is accessible only to current and former S7clear colleagues and the relevant conditions are set forth in the Alumni Center website.
- Your rights
Where granted by applicable law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.
If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at firstname.lastname@example.org. To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.
In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.
If you have registered for S7clear newsletter or alerts, or you receive invitations to survey or events from S7clear and you prefer not to receive future email communications from us, please review the communications settings in your profile on s7clear.com, follow the instructions on the page of the Site where you have provided such information, subscribed or registered or write to email@example.com to unsubscribe from all S7clear communications.
- Your California privacy rights
In addition, under California law, you may have the right (up to two times in any 12-month period) to request more information about S7clear’s collection, use, disclosure, and sale of personal data about you including:
The categories of personal data about you that we have collected in the preceding 12 months and the categories of sources of that information,
The categories of sources from which we have collected that information in the preceding 12 months,
The commercial or business reason(s) we have collected, used, disclosed, or sold that information, and
The categories of third parties to whom we have disclosed or sold that information in the preceding 12 months.
In addition, upon receipt of a verifiable request from you establishing your identity, you may have the right to know about the specific pieces of personal data that we have collected about you and/or shared with third parties in the preceding 12 months.
You may also have the right to request deletion of personal data about you that we have collected or maintain, which we will honor subject to certain limitations set forth in California law.
If you are a California consumer and you or your authorized agent would like to exercise your privacy rights, please contact us at firstname.lastname@example.org,. When we process your request, we require you to provide certain personal data about you in order to verify your identity in accordance with requirements under CCPA. This may include your first and last name, email address, physical address, telephone number, and information about your relationship with us or other information needed to verify your identity. S7clear will not discriminate against you based on your exercise of any of these rights.