Cention takes your privacy seriously.
The capitalized Conditions used in this Policy but not defined herein shall have the same meaning as defined in the Conditions of Service (“Conditions”).
WHOM DOES THIS NOTICE APPLY TO?
This Notice applies to (i) entities or individuals, excluding End-Users and Users, who have subscribed to our Service(s) and have agreed to the Conditions (hereinafter referred to as the “Customer”) and (ii) individuals (“Individuals”) from whom Cention collects data as a controller as specified below.
WHAT PERSONAL DATA DOES CENTION COLLECT AND WHY?
A) Personal Data we collect and process for our own purposes: Collected Data
When you visit our Websites or participate in Cention’s events, Cention may collect information, which may include Personal Data, from Individuals as set forth below (collectively referred to as “Collected Data”). For the purposes of General Data Protection Regulation (GDPR), Cention shall be the controller for the Collected Data – this means that Cention decides what Collected Data is processed and why. When does Cention process Collected Data?
DATA DOES CENTION COLLECT AND WHY?
When you subscribe and sign-up to any of our Service(s), we may collect your (i) contact information such as name, e-mail address, mailing address, IP address, geographic location and phone; (ii) billing information, such as billing address; (iii) name and e-mail address when Account admin/Agent(s) provide feedback from within the Service(s); and (iv) unique identifiers, such as username, account number or password. Subject to this Policy and the Conditions, we will use such data, including without limitation, to (i) provide you the Service(s); (ii) send you communication from the Service(s); (iii) assess needs of your business to determine or suggest suitable Service(s); (iv) send you requested information about the Service(s); (v) respond to customer service requests, questions and concerns; (vi) administer your Account; (vii) send you promotional and marketing communications; and (viii) facilitate your transactions with other users when you use our Service(s).
When you attend an event conducted by Cention, including webinars or seminars, we may collect your contact information such as name, e-mail address, designation and company name. Subject to this Notice, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Service(s); (ii) send you requested information about the Service(s); (iii) send you promotional and marketing communications; and (iv) respond to your questions and concerns.
When you actively subscribe to our newsletters, we collect your e-mail address to share our newsletters with you. Subject to this Notice, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Service(s); (ii) send you requested information about the Service(s); (iii) send you promotional and marketing communications (where you have requested us to do so); and (iv) respond to your questions and concerns.
4) Clear Gifs and Log Files.
Apart from the aforementioned information collected by us, we automatically receive and record certain Personal Data of yours when You visit our Websites. This includes device model, IP address, the type of browser being used, usage pattern through cookies and browser settings, query logs and product usage logs. We also collect clicks, scrolls, conversion and drop-off on our Websites and Service(s) to render user journey at real-time. Subject to this Policy, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Service(s); (ii) send you requested information about the Service(s); (iii) respond to customer service requests, questions and concerns; and (iv) for analytical purposes. You authorize Cention and its service providers to perform analytics on such Collected Data, to (i) improve, enhance, support and operate the Websites; and (ii) compile statistical reports and record insights into usage patterns. You acknowledge that Cention uses Collected Data, as the case may be, for these purposes.
6) Marketing communications.
We may use your e-mail address, collected as part of Collected Data, to send our newsletters and/or marketing communications about our products and services. If you no longer wish to receive these communications, you can opt out by following the instructions contained in the e-mails you receive or by contacting us at email@example.com.
What is our legal basis for processing Personal Data (EEA visitors only)?
If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we need the Personal Data where the processing is in our legitimate interests or rely upon your consent where we are legally required to do so and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person. If we ask you to provide Personal Data to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided below.
Data we process on your behalf: Service Data
We only process Service Data as per our Customer’s instructions. For purposes of the GDPR, we are the processor and not the controller of the Service Data. Service Data, as defined in the Conditions, means all electronic data, text, messages or other materials, including Personal Data of Users and End-Users, submitted to the Service(s) by our Customers through Customer’s Account in connection with Customer’s use of the Service(s), including data collected under “Other Information” and “Mobile Applications” below. Our EEA based Customers are the “controllers” of that data and are responsible for compliance with the applicable data protection law. We work with our Customers to help them with tools to comply with regulations. If you are our Customer from EEA, then in your role as a controller, you are authorizing, on behalf of you and your authorized agents and End-Users, and representing that you have the authority to provide such authorization to the processing and transfer of Personal Data in and to other countries which may have different privacy laws from your or their country of residence. We will take all steps reasonably necessary to ensure that the Service Data is treated securely and in accordance with this Policy. We do not own, control or direct the use of Service Data, and in fact we are largely unaware of what information is being stored on our platform and only access such information as reasonably necessary to provide the Service(s) (including to respond to support requests), as otherwise authorized by Customers or as required by law. As the controller, it shall be your responsibility to inform the End-Users about the processing, and, where required, obtain necessary consent or authorization for any Personal Data that is collected as part of the Service Data through your use of the Service(s). As the processors of Personal Data on behalf of our Customers, we follow Customer’s instructions with respect to the Service Data to the extent consistent with the functionality of our Service(s). In doing so, we implement technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, Personal Data. Other Information. Where a User or End-User uses the Service(s), we automatically receive and record certain information of such user. This information includes device model, IP address, the type of browser being used, usage pattern through cookies and browser settings, query logs and product usage logs (collectively referred to as “Other Information”). Improving and enhancing our Service(s). You expressly authorize us and the service providers we use to process the Service Data in our systems to (i) provide, improve, enhance, support and operate the Service(s) and its availability; (ii) develop new products and services; and (iii) compile statistical reports and record insights into usage patterns.
SOCIAL MEDIA FEATURES
SHARING OF PERSONAL DATA
Except as outlined in this Policy and the Conditions, Personal Data contained in Collected Data and Service Data will never be sold to or shared with other companies or organizations for commercial purposes. We process Personal Data in Singapore and the European Economic Area (“EEA”) and in other countries through third parties that we may use. Third parties that we utilize to assist in providing the Service(s) with whom Service Data may be shared (“Sub-Processors”) can be required by contacting us using the contact details provided below. Further, we may transfer Personal Data to our Group Companies for the purposes identified in the Conditions and this Policy. All such transfers are covered by the service agreements with the relevant recipients and we have taken appropriate safeguards to ensure that your Personal Data will remain protected in accordance with this Privacy Notice. Further details can be provided upon request. Subject to the Conditions and this Policy, we and our Group Companies shall have the right to access Customer’s Account and to process Service Data solely to the extent necessary to provide, enhance and improve the Service(s), including, without limitation, in response to Customer’s support requests. Our Sub-Processors will only be given access to Customer’s Account and Service Data as is reasonably necessary to provide the Service(s) and will be subject to confidentiality obligations in their service agreements.
HOW DOES CENTION KEEP PERSONAL DATA SECURE?
We use appropriate technical and organizational measures to protect the Personal Data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.
EEA SPECIFIC RIGHTS
A) Collected Data If you are an individual resident in EEA, you have the following data protection rights regarding Collected Data:
- If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us.
- You can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by following the information on how to unsubscribe within the marketing e-mails we send you.
- Similarly, if we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. If you seek access to, or wish to correct, update, modify or delete Personal Data (hereinafter referred to as a “Request”) which forms a part of Collected Data, please contact us at firstname.lastname@example.org. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
B) Service Data If you seek access to, or wish to correct, update, modify or delete Personal Data (hereinafter referred to as a “Request”) which is part of the Service Data and processed by us on behalf of our Customer, you should direct your query to our Customer i.e., the controller. If you are a Customer of our Service(s) and wish execute a Request on behalf of your Users and End-Users in connection with Service Data, you will find the tools to do so within our Service(s).
If you are our Customer, we will send you announcements related to the Service(s) on occasions when it is necessary to do so. For instance, if our Service(s) is temporarily suspended for maintenance, we might send you an e-mail. Generally, you may not opt-out of communications which are not promotional in nature. If you do not wish to receive them, you may contact us at email@example.com.
RETENTION OF PERSONAL DATA
If you wish to request that we no longer use your Collected Data, please contact us at firstname.lastname@example.org. Except as otherwise set forth below, Personal Data contained in the Service Data is retained and deleted in accordance with the settings you choose to add to our Data Privacy Tools and the Conditions. If you are a Customer of our Service Cention, and if you have raised a Request for deletion of a User, please note that, for business continuity purposes, deleting the User does not delete business-specific organization-owned data created and contributed to by the User including without limitation, knowledgebase articles, notes, forum topics/comments, support, surveys, automation and dispatcher rules, templates, contacts, companies, tags, conversations in the errands, etc. The deleted User’s Personal Data will then be anonymized within the Service.
LINKS TO THIRD PARTY SITES
Our Websites contain links to other websites that are not owned or controlled by Cention. Please be aware that we are not responsible for the privacy practices of such other websites or third parties. We encourage you to be aware when you leave our Websites and to read the privacy policies of each and every website that collects Personal Data.
Amendments to this Policy will be posted to this URL and will be effective when posted. If we make any material changes, we will notify you by means of a notice on this Website prior to the change becoming effective and if you are our Customer, via e-mail. Provided we will not be notifying you if we amend the Policy to make addition, deletions or modifications to the list of cookies from time to time to keep the list of cookies current and accurate. You should frequently visit this Policy to check for amendments. Your continued use of our Websites or the Service(s) following the posting of any amendment, modification, or change to this Policy shall constitute your acceptance of the amendments to this Policy. You can choose to discontinue use of the Websites or Service(s), if you do not accept the Conditions of this Policy, or any modified version of this Policy.
We, including our Group Companies reserve the right to disclose your personal data contained in Collected Data and Service Data as required by applicable law, in response to lawful requests by public authorities, including meeting national security or law enforcement requirements and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or other legal process served on us. Collected Data and Service Data will also be shared between our Group Companies for the activities permitted under the Conditions and this Policy. In the event Cention goes through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, Customer’s Account, Collected Data and Service Data will likely be among the assets transferred. A prominent notice will be displayed on our Websites to intimate you of any such change in ownership or control and Customers will be notified via an e-mail from email@example.com.