Data Protection Statement and Privacy Policy

1. Purpose

OpenSymmetry is committed to protecting the privacy and security of your personal information. This privacy notice describes how OpenSymmetry collects and uses personal information. It applies to all prospects and customers of our professional services and users of our website.

This privacy notices applies when OpenSymmetry is a “data controller”. This means that we are responsible for deciding how we hold and use the personal information we collect about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

Notice to California Residents

For California residents, please see the California Privacy Notice for more information about how we collect, use, and share your personal information and the rights you have with respect to your personal information.

2. Data we collect

We collect, store, and use the following information about you:

• Information you give us through OpenSymmetry’s website via a form, application, contact request, or other request for information
• Information you may have posted on any blogs, forums, and any other social media applications that we provide
• Information you provided to a third party to attend a conference, training course, or demonstration that we sponsor
• Information you provided directly to us at a third party to attend a conference, training course, or demonstration that we sponsor
• Information provided through using cookies on our company website, including your location data and your activity on our website. More information on how we use cookies and other tracking technologies can be found in our cookies notice.

The personal information we collect typically includes the following: full name, email address, work address, phone number, job title, employer, location of employment, and your activity on blogs and social media that we provide. In some circumstances, such as when we provide lunch and dinner at a training course or conference, we may collect more sensitive types of personal information about you, such as dietary restrictions and food allergies.

3. How your personal information is collected 

We collect personal information about you in several ways.

• We collect the information you give us via the company website or by phone and email.
• We may collect your information through your attendance of or participation in events that we sponsor, such as conferences, online trainings, webinars, surveys, and demonstrations of our professional services.
• We may collect your information from other companies who sell us or share with us your information.
• We may collect information from places that are publicly available, such as blogs, social media and networking sites.
• We may collect information using cookies and other tracking technologies through our company website. 

4. How we will use information about you

We will use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• To contact you about products and services
• To perform a contract we have entered into with you
• To comply with a legal obligation
• Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests

Situations in which we will use your personal information

We need the categories of information in the list above primarily to allow us to contact you about service offerings and to perform a contract we may have entered into with you. In some cases, we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

• To contact you about product or service offerings
• To provide information about conferences, online trainings, webinars, surveys, and demonstrations of our professional services
• To perform a contract we have entered into with you
• To comply with applicable legal or regulatory requirements

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Cookies

A cookie is a small text file that a website or app sends to a user’s device.

Once you agree to accept cookies, the file is added, and the cookie analyzes your web traffic on that site. Cookies allow web applications to respond to you as an individual and store helpful information to enhance your experience with a site. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences, such as your preferred language, device settings, browsing activities and other useful information. A cookie does not allow us access to your computer or any information about you, other than the data you choose to share with us. Most browsers automatically accept cookies, but you can modify your browser settings to decline cookies.

Cookies we use

• Essential Cookies
  These cookies track your activity on our website and are used to provide essential security measures and affect the functioning of this website. These cookies are not stored by OpenSymmetry after you close your browser. 
• Analytics Cookies
  OpenSymmetry utilizes Google Analytics. Google Analytics’ cookies track activity about how visitors use this website. These cookies collect information about a user’s website activity and aggregate it to give us a better understanding of how our website is being used. For more information on how Google Analytics uses cookies visit www.google.com/policies/privacy/partners/. 
• Marketing Cookies
  OpenSymmetry utilizes HubSpot. HubSpot uses cookies to recognize and track activity on this website and connect it to the personal information you may provide to us via an online form. These cookies also allow us to understand which services and offerings may most appeal to you and send you the most relevant marketing material.  
• Third Party Cookies
  You may encounter embedded content on the website, such as links to event details and trainings, third party blogs, and partners websites. These linked websites will use their own cookies. OpenSymmetry does not control these websites or their owner’s use of cookies, even if you are directed to them from our website.  

6. Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

• Where we have notified you of the decision and given you twenty-one (21) days to request a reconsideration
• Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights
• In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

7. Data sharing

We may share your data with third parties, including other entities owned or controlled by OpenSymmetry and third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information inside and outside of the EU. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties? 

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities owned or controlled by OpenSymmetry. The following activities are carried out by third-party service providers: marketing automation, lead generation, and ERP and CRM services.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with third-party service providers or other entities in our group?

We will share your personal information with third-party service providers or other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganization or group restructuring exercise, for system maintenance support and hosting of data.

For EU residents: Transferring information outside the European Union 

For residents in the European Economic Area, we will transfer the personal information we collect about you to the United States and may transfer your personal information to another country in which we conduct business, such as India, Malaysia, Australia, South Africa, or Canada. Your personal information may also be transferred, stored or processed in a country where our service providers and/or partners are located. For each of these countries, including the United States, there may not be an adequacy decision by the European Commission. This means that the country to which we transfer your data may not be deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information receives an adequate level of protection we have put in place the OpenSymmetry Data Privacy Policy. This policy provides that your personal information will be treated by all OpenSymmetry subsidiaries and affiliates in a way that is consistent with and which respects the EU and UK laws on data protection. For transfers of personal information to our service providers and partners, we have implemented the European Commission’s Standard Contractual Clauses. If you require further information about these protective measures, please email privacy@opensymmetry.com.

8. Data Security

We have measures in place to protect your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Access to your personal information is limited to those employees, agents, contractors and other third parties who have a business need to know. Third parties will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

9. Data Retention

We will retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data 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 associated with you, in which case we may use such information without further notice to you. 

10. Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure (Right to be Forgotten) of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party. For California residents, this transfer of personal information must take place within 45 days of the request.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

11. Right to withdraw consent 

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

12. Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time. When this privacy notice is updated, we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact the data privacy manager at privacy@opensymmetry.com.