Last updated: 12 December 2018
1. Important Information and Who We Are
Uncountable Inc. is the “data controller” of your personal information. In simple terms, this means that we: (i) “control” your personal information, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal information, but only to the extent that we have informed you about the use or are otherwise permitted by law.
How to contact us or make complaints
If European Union data protection laws apply to your personal information, you have the right to make a complaint at any time to the relevant European Union supervisory authority. We always appreciate the chance to deal with your concerns before you approach any supervisory authority, so please contact us in the first instance.
It is important that the personal information we hold about you is accurate and up-to-date. Please keep us informed if your personal information changes during your relationship with us.
2. The Types of Personal Information We Collect About You
The types of personal information we collect, use and store about you will depend on the product or service you have requested from us and/or the nature of your interaction with us. When using the Site, we collect and process the following types of personal information (depending on the nature of your interaction with us):
· your name, age/date of birth and gender;
· personal, device and business contact information (such as your email address, postal address, phone number and IP address);
· your communication and marketing preferences;
· other personal information that you submit to us, such as information you provide to correspond with us in relation to inquiries; and
· other publicly available personal information, including any which you have shared via a public platform (such as a LinkedIn page).
We do not collect any special category personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How We Collect Your Personal Information
When you enter and browse the Site, we may collect two different types of information about you: information you provide to us, and information we collect through technology or from third parties.
Personal Information You Provide to Us
You may voluntarily provide personal information via the Site in online forms and conversations and in other correspondence (including via email and telephone), for example, in a request to contact us. We may collect and retain a record of all communications with you.
Personal Information We Collect Through Technology or from Third Parties
We may collect information about you through technology automatically as you navigate the Site. For example, we may collect your IP address each time you request a page during a visit to the Site. At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site. We may also collect information regarding your browser version and your operating system.
The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send our Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails.
In connection with an employment inquiry, we collect data from third parties regarding your work authorisation status, education history, employment history and professional designations, and other information about your qualifications.
4. How We Use Your Personal Information
We will use your personal information for the following purposes, and pursuant to the corresponding legal bases:
1. Purpose: To enter into, and perform, contracts with you that you or your employer have requested, including by sending administrative emails to you in relation to such contractual arrangement. Legal Basis: Performance of a contract with you.
3. Purpose: To improve the Site and products and services that we offer, including tailoring the Site to the needs of all users; recommending options that match any stated preferences; and notifying you about changes to our services. Legal Basis: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
4. Purpose: To keep a record of your relationship with us. Legal Bases: (a) Necessary for our legitimate interests. (b) Necessary to comply with a legal obligation.
We may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your data.
No automated decision making, including profiling, is used when processing your personal information.
You will receive marketing communications from us if you have requested information from us or purchased products or services from us, and, in each case, you have expressly consented to receiving that marketing or, on the basis of our legitimate interests, we believe that you would expect to receive that communication. You can ask us to stop sending you marketing messages at any time by clicking the ‘unsubscribe’ link contained in a communication, responding to the communication with an indication that you would like to stop receiving that communication, or by use or by contacting us at firstname.lastname@example.org, Attn: Webmaster, Uncountable or Uncountable GmbH.
Where you opt-out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a service provided by us to you or your company (which we will continue to process in order to perform a contract with you, on the basis of our legitimate interests, or as a result of our regulatory or legal obligations).
5. Who We Share Your Personal Information With
We store your personal information and share it with our affiliates, including Uncountable GmbH, our wholly-owned German subsidiary. We may use or disclose this information for marketing, research and other business purposes, and we may associate your personal information with other information we collect about you, such as details about your usage patterns and interests, but we will not sell this information to unaffiliated third parties.
We use service providers to operate the Site and employ other persons to perform work on our behalf (including lawyers, auditors and other professional advisers). These companies and individuals may have access to your personal information, but only as needed to perform their functions. We make sure that these companies and individuals enter into an appropriate agreement with us in respect of data processing and meet our standards for data security, under which they may not use your personal information for another purpose or share your personal information with any organization without our consent (except where required to do so by applicable laws).
Additionally, in the event that we choose to merge, sell or transfer all or parts of the shares, businesses or assets of Uncountable, or we acquire or merge with another entity, whether an affiliate or a third party, your personal information may be one of the assets that we may transfer to our acquirers or successors.
6. How We Use Your Non-Personal Information
Non-personal information is information that does not allow you to be identified or identifiable. We may use this information to understand better how our visitors use the Site, research our visitors’ interests and behavior, improve the Site, provide visitors with customized services and information, and for other similar purposes. We may share this information with others in any manner permitted by law.
7. How We Protect Your Personal Information
We endeavor to protect your personal information. We use technical, administrative and physical methods to maintain the integrity and security of our electronic systems and protect your personal information. Please be aware that no security measures are perfect or impenetrable and that third parties may unlawfully intercept or access transmissions or private communications. However, we cannot guarantee the security of your data transmitted via the Site and therefore any transmission is at your own risk. We are not responsible or liable for any damages arising out of or in connection with your disclosure of your personal information.
8. Do Not Track and Disclosure of Information for Direct Marketing to California residents
We do not track our customers or Site users over time and across third party websites to provide targeted advertising and, therefore, the Site does not respond to Do Not Track signals. California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com (Attn: Webmaster, Uncountable).
10. How Long We Retain Your Personal Information For
We will retain your personal information only for so long as we need the personal information for the purposes it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. unless a longer retention period is required under applicable law.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information (so that it can no longer be used to identify you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
For further information regarding how long we retain your personal information, please contact firstname.lastname@example.org, Attn: Webmaster, Uncountable or Uncountable GmbH.
11. International Transfers of Your Personal Information
When we transfer your personal information to countries located outside of the European Economic Area (“EEA”), such transfers are made in accordance with applicable data protection laws. Such transfers include when we are provided with personal information that you may have provided to our Germany subsidiary. For more information on the manner in which we legally protect your personal information when it is transferred outside the EEA, please contact email@example.com, Attn: Webmaster, Uncountable or Uncountable GmbH.
12. Your rights
If European Union data protection laws (or any other applicable law that grants such rights) apply to our use of your personal information, you have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. We have explained these individual rights and controls below. To exercise these rights and controls (and to find out if they are applicable to you), please contact us at firstname.lastname@example.org, Attn: Webmaster, Uncountable or Uncountable GmbH.
· Access: You have the right to ask for a copy of the personal information that we hold about you free of charge, however we may charge a ‘reasonable fee’ if we think that your request is excessive, to help us cover the costs of locating the information you have requested. We will respond to your request as soon as possible and (save for in certain circumstances) within one month.
· Correction: If there are any inaccuracies in the information we hold about you, please contact us and we will correct them.
· Deletion: If you think that we shouldn’t be holding or processing your personal information any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
· Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (unless the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal information for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
· Object: You have the right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Request the transfer: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means. Please note that this right only applies to automated information which you initially provided consent for us to use or where we use the information to perform a contract with you.
· Withdrawal of consent: If you previously gave us your consent to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
A cookie cannot give us access to your computer or to information beyond what you provide us and we don't store personal information such as your name or address in cookies we create, but we do use encrypted information gathered from them to help improve your experience of the Site.
You may refuse to accept cookies or can turn off cookies by activating the appropriate setting on your browser; however doing so may prevent you from properly accessing certain parts of the Site. You can also choose to have your computer warn you each time a cookie is being sent. Each browser is different, so look at your browser Help menu to learn the correct way to modify your cookie settings.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.