Outermost Technology Privacy Policy (EU)

Last updated October 4, 2019

Outermost Technology LLC. (“Outermost Technology”) operates the Outermost Technology website and Outermost Technology Community online forum (collectively with all content, services and products available on or through the website, the “Website”). It is Outermost Technology’s policy to respect your privacy regarding any information we may collect while operating the Website or when you otherwise engage with Outermost Technology. This Privacy Policy is governed by our Terms of Service.

This Privacy Policy is intended to help you understand:

For the purposes of the General Data Protection Regulation of the European Union (the “GDPR”), Outermost Technology is the Data Controller with respect to information collected through the Website or otherwise pursuant to this Privacy Policy. Outermost Technology’s contact information can be found in the “Contact Us” section at the bottom of this Privacy Policy

Website and Community Visitors

Like most website operators, Outermost Technology collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Outermost Technology’s purpose in collecting non-personally-identifying information is to better understand how Outermost Technology’s visitors use the Website. We may choose to aggregate this non-personally-identifying information with your personal data for analytics and other purposes.

Children

The Website is not intended for or directed to persons under the age of 16, and we will not knowingly collect information from such persons. Any person who provides information to us through registration or in any other manner on the Website represents to Outermost Technology that they are 16 years of age or older. If we learn that a child under 16 has submitted personal data to us, we will attempt to delete the information as soon as possible.

Gathering of Personal Data

Persons who visit the Website or otherwise engage with Outermost Technology choose to interact with Outermost Technology in ways that require Outermost Technology to gather personal data that allows them to be individually identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

The amount and type of information that Outermost Technology gathers depends on the nature of the interaction. For example, we ask visitors who sign up for the Outermost Technology Community to provide a username, email address, geographic location, and other information including main area of specialty and name of employer. In any case, Outermost Technology collects such information only as far as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with Outermost Technology. Outermost Technology does not disclose personal data other than as described below. Visitors can always refuse to supply personal data (except to the extent a user’s IP address or other Technical Data supplied by their device may constitute personal data), with the caveat that it may prevent them from engaging in certain Website-related activities. Outermost Technology will only use your personal data, including your contact details, for marketing purposes if doing so is within the scope of our legitimate interests or you have given your explicit consent for us to do so. Outermost Technology will never sell, rent, or provide user information to other vendors or other companies that seek to market or sell products by using such user information.

We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

Aggregated Statistics

Outermost Technology may collect statistics about the behavior of visitors to our Website. For instance, Outermost Technology may monitor the most popular content on the Website or report the most popular discussion groups in the Outermost Technology Community. However, Outermost Technology does not disclose personal data other than as described in this Privacy Policy.

How your Personal Data is Collected

We use different methods to collect data from and about you. These include:

Disclosure and Use of Certain Personal Data

Outermost Technology discloses personal data to those of its employees, service providers, contractors and affiliated organizations that (i) need to know that information in order to process it on Outermost Technology’s behalf or to provide services available on or through the Website, and (ii) that have agreed not to disclose it to others. Some of those employees, service providers, contractors and affiliated organizations may be located outside of your home country. Please see the information concerning international transfers set forth below regarding such employees, service providers, contractors and affiliated organizations.

How We Use Your Personal Data and Our Legal Basis for Doing So

We will only use your personal data as permissible by law. Most commonly, we will use your personal data in the following circumstances:

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via direct mail, email, or text message where we do not have an existing business relationship or other legitimate interest in doing so. If we do rely on consent, you have the right to withdraw consent to marketing at any time by contacting us in the manner set forth in this Privacy Policy. If we do not rely on consent, you have the right to object to our processing of your personal data in any case, again, by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds, we are relying on to process your personal data where more than one ground has been set out in the table below.

 

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you, your employer or principal as a new or potential customer

Identity

(b) Contact

Performance of a contract with you

(b) Necessary for our legitimate interests (operating our business)

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy policy

Asking you to leave a review or take a survey

Identity

Contact

Profile

Marketing and Communications

Performance of a contract with you

Necessary to comply with a legal obligation

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Identity

Contact

Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

Necessary to comply with a legal obligation

To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Identity

Contact

Profile

Usage

Marketing and Communications

Technical

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)

To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences

Technical

Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Identity

Contact

Technical

Usage

Profile

Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

If you are (i) a vendor or service provider, or (ii) a representative of a vendor or service provider, to manage our relationship with you (in the case of (i)) or to manage our relationship with the vendor or service provider you represent (in the case of (ii))

Identity

Contact

Technical

Usage

Profile

Financial

Marketing and Communications

To enter into or perform a contract with the vendor or service provider.

Necessary for our legitimate interests in operating our business.

With your consent

All types of data

We may use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote our products/services, with your permission.

You can ask us to stop sending you marketing messages at any time by clicking the link at the bottom of all marketing emails or by emailing a request to privacy@outermost-tech.com.

Disclosures of your Personal Data

Outermost Technology discloses personal data when required to do so by law, or when Outermost Technology believes in good faith that disclosure is reasonably necessary to protect the property or rights of Outermost Technology, third parties or the public at large. Additionally, Outermost Technology may disclose personal data in connection with a sale or merger with another entity or if Outermost Technology should ever file for bankruptcy or have its assets sold to another entity.

We may disclose your personal data to our employees, contractors, or third party service partners. These third party service partners are listed at the end of this document on Exhibit A. Some of these service partners use “cookies” or other tracking devices on the Website, which are software programs or other systems that collect information about your use of our services. As described below, we will only transfer your information internationally (for example, to information technology vendors in other countries) where we believe appropriate safeguards are in place to protect your information.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Cookies

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Outermost Technology uses cookies to help Outermost Technology identify and track visitors, their usage of the Website, their Website access preferences and to maintain extended user login sessions for a better user experience. Outermost Technology visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Website, with the drawback that certain features of the Website may not function properly without the aid of cookies.

International Transfers

Our business operates principally in the United States of America and to the extent we process your data directly we will do so in the United States. If you reside in the European Union, we will only transfer your data to third parties outside of the European Economic Area ("EEA") (a) if we have first obtained your prior consent; or (b) after taking such measures as are necessary to ensure the transfer is in compliance with the requirements of the GDPR. Such measures may include (without limitation) transferring your data to a recipient in a country that the European Commission has decided provides adequate protection for personal data, to a recipient that has achieved binding corporate rules authorization in accordance with the GDPR, to a recipient in the United States that has certified its compliance with the EU-US Privacy Shield, or to a recipient that has executed standard contractual clauses adopted or approved by the European Commission.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Without limiting the previous sentence, if we have a business relationship with you or an entity you represent, we will retain your personal data for at least the duration of that relationship. Otherwise, the length of time for which we retain information will depend on the nature of the information. Specifically:

Profile Data and Identity Data: We retain your profile data and identity data for as long as your account is active and a reasonable period thereafter in case you decide to re-activate your account. Where we retain information for service improvement and development, we only use the information to uncover collective insights about the use of our services, not to specifically analyze personal characteristics about you.

Information you share on the Outermost Technology Community: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow other users to make full use of the Outermost Technology Community. For example, we may continue to display content you provided such as posts or responses.

Marketing information: If you have elected to receive marketing communications from us or if we have determined that we have a legitimate interest in marketing to you, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

Links to Third Party Sites

The Website may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third-party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.

Your Legal Rights

You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and some limitations.

Your Choices:

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, to request your information in a structured, electronic format, the right to have your personal data rectified if it is incorrect, the right to withdraw your consent to processing of your personal data (where the consent is the lawful basis for such processing) and, if the GDPR applies, the right to lodge a complaint with a supervisory authority, which may be the Data Protection Authority in the country where you reside.

You can exercise some of the choices by accessing the Outermost Technology Community or the Website and using settings available within your account. Otherwise, you can contact us to exercise your rights using the contact information below.

You may opt out of receiving marketing communications and automated messages from us by using the unsubscribe link within each email or by contacting us to have your contact information removed from all promotional and transactional emails. However, even after you opt out from receiving promotional messages from us, you will continue to receive certain transactional messages from us regarding our products and services such as payment failure notices or account suspension notices sent via email.

Contact Us

Please email, call or write us for any requests or questions:

privacy@outermost-tech.com
+1 408 721 6800
Outermost Technology, LLC.
Attn: Privacy
2975 Scott Boulevard, Suite 220
Santa Clara, CA 95054
USA

To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.

Consent and Privacy Policy Changes

By using our Website or otherwise interacting with Outermost Technology, you agree to this Privacy Policy. Although most changes are likely to be minor, Outermost Technology may change its Privacy Policy from time to time. The date of the most recent update of this document will always be displayed at the beginning of this page. Outermost Technology encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change provided, however, where we feel it is necessary and appropriate, we may also email you regarding changes to this Privacy Policy.

Exhibit A

Third Party Processors/Subprocessors of Your Data

To support the Website and the Outermost Technology Community, we use different service providers that may store and process personal data about you. This section provides important information about the identity, location, and role of these Data Processors/Subprocessors. We use different types of Processors/Subprocessors to perform various functions as explained in the table below.

Processor/Subprocessor

Location

Role

Salesforce

USA

CRM

Microsoft

USA

Office 365 – email servers and file storage

Google Analytics and Google Tag Manager

USA

To identify returning users to Outermost Technology Website and to analyze Website user behavior, for example, the number of pages viewed and the duration of time spent by a user on the Website.

Facebook Business Manager

USA

To identify returning users to Outermost Technology Facebook page and to analyze user behavior, for example, the number of pages viewed and the duration of time spent by a user on the page as well as the effect of advertisement campaigns

LinkedIn

USA

To identify returning users to Outermost Technology LinkedIn page and to analyze user behavior, for example, the number of pages viewed and the duration of time spent by a user on the page as well as the effect of advertisement campaigns