Privacy Notice
Revised May 7, 2024
1. Overview and Scope
2. Information We Collect
3. Purposes of Collection
4. Disclosure of Your Information
5. Cookies and Tracking Technologies
6. Your Choices
7. Retention
8. External Links and Features
9. Security
10. Children’s Information
11. Changes to this Notice
12. Contact Us
13. Additional Privacy Information for California Residents
14. Additional Privacy Information for EEA and UK Residents
1. OVERVIEW AND SCOPE
ST Engineering iDirect, Inc. dba iDirect, ST Engineering (Europe) CY NV and ST Engineering iDirect (UK) Limited and its affiliates (“iDirect”, “we”, “us” or “our”) respect the privacy of our users’ personal information.
This Privacy Notice (“Notice”) applies to information that we collect both online and offline from persons, such as current, former and prospective customers, vendors and partners (“you”, “your” or “user”), including through uses of our website, www.idirect.net (“Website”); from other websites or from portals operated by us from which you are accessing this Notice; through our social media pages or our mobile applications (“App” or “Apps”); when you trial, demo, lawfully receive or purchase our satellite products or solutions; in connection with our marketing efforts; when you use our professional services; or when you otherwise communicate, interact, or engage with us regarding our professional services (all together, “Services”). This Notice explains how we collect and use information, including personal information, and how you can exercise your privacy choices.
If you are a resident of California, please also refer to Section 13. Additional Privacy Information for California Residents below for more information about the categories of personal information we collect and your rights under California privacy laws.
If you are a resident of the European Economic Area or the United Kingdom, please also refer to Section 14. Additional Privacy Information for EEA and UK Residents below for more information about the personal information we collect and your rights.
For users outside the EEA and the UK: Use of our Services and any dispute over privacy is subject to this Notice and our Terms of Use, including applicable terms governing limitations on damages and the resolution of disputes.
For information about the privacy choices you have regarding your personal information, please see Section 6. Your Choices below.
Please note that, depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our information practices. For example, this Notice does not apply to our employees in the context of our employment relationship with them.
2. INFORMATION WE COLLECT
We collect, process, and retain information, including personal information, from you and any device you may use when you use or interact with our Services, and in the ways described below.
Personal Information You Provide. The personal information you provide to us helps us learn more about, and provide you with, the use of the Services. We collect personal information that you submit to us voluntarily in the course of correspondence, registration, and as otherwise identified below. We receive and store personal information you provide to us, including questions or comments you submit via our online forms or Apps or from filling out a request form, such as a survey or contact request. If you submit to us any personal information relating to other people or to our service providers in connection with our Services, you represent that you (i) have informed these other parties about the content of this Notice, (ii) have the authority to submit personal information relating to other people, and (iii) permit us to use the information in accordance with this Notice.
We also collect and store personal information you may provide when applying for a position with iDirect, which (depending on the circumstances), can include your name, address, telephone number, e-mail address, desired salary, education level, professional experience, and other personal information. If you are a California resident, or are applying for a job with an iDirect EU or UK entity, please see our California Candidate Notice or our EU/UK Candidate Notice for more information.
If you email us (or contact us otherwise), we may retain a record of such email (or other) communication (and attachments), including your email address, name, content of your email, and our response.
For some Services, a registered user may be provided a unique username and password that enables access to the Services. We may track the use of those usernames and passwords in order to collect and maintain records of individual transactions conducted through our products, solutions and Services.
Personal information requested on a form or application is required in order to fulfill your request or perform our contractual obligations to you. If you do not provide such personal information, we will be unable to respond to your request or perform our obligations to you.
Information from Social Media. When you interact with us through a social media platform, we may collect the personal information that you make available on that platform, including your account ID or username and other information included in your posts.
Information We Collect Automatically. We automatically collect personal information related to your use of our Services, including from cookies, and other similar technologies, such as:
- Device and Browsing Information. When you visit our Website or use our Services, we may collect Internet Protocol (IP) address, browser type, domain name, access times, date/time stamps, operating system, language, device type, unique ID, internet service provider, referring and exiting Uniform Resource Locators (URLs), clickstream data, and similar device and browsing information.
- Activities and Usage. We may collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, your interactions with us within the Services, and other activity and usage information.
- Location Information. We may collect or derive general location information about you, such as through your IP address. In addition, when you or your company, employee, or principal use our installation services, we receive information about the location of the satellite antenna or terminal(s) you own or are authorized to access. This location information may be necessary to provide the Services.
For more information about our use of cookies and other similar technologies, please see Section 5. Cookies and Tracking Technologies below.
Other Information. “Other information” is any information that is not personal information because it does not reveal your specific identity or does not directly or indirectly relate to an identified or identifiable person. This might include, for instance, aggregate or statistical data; certain types of information collected through cookies, and other technologies; or aggregated information. We use this information to facilitate our operation of the Website and for other purposes described in Section 5. Cookies and Tracking Technologies below.
Information We Collect from Other Sources. We may receive personal information about you from other sources, like telephone, fax, or email, from vendors or service providers in connection with the Services, as well as from nonaffiliated entities to whom you have voluntarily provided information. We may supplement this information we collect with information from such nonaffiliated entities or that we collect offline, such as information collected over the phone or in person.
3. PURPOSES OF COLLECTION
We collect the information as described above for the following reasons:
- communicate with you and respond to your inquiries or requests (e.g., requested materials, a requested newsletter), including as part of the “Contact Us” feature on our Website;
- send administrative information to you (e.g., information regarding the changes to our terms and conditions);
- provide you with customer service and customer support related to troubleshooting in connection with our products, solutions and Services;
- manage the planning of events and webinars, and other management-related purposes, such as registration, attendance, connecting you with other event attendees, and contacting you about relevant events, products, solutions and Services;
- carry out our obligations and enforce our rights arising from contracts entered into between you and iDirect, including for billing and payment collection;
- send you marketing communications, including via email and SMS in compliance with applicable laws, that we believe may be of interest to you;
- present products, solutions and offers tailored to you;
- tailor your experiences with our Services to meet your special interests and needs;
- engage in one of the following activities: data analysis, audits, fraud monitoring and prevention, developing new products and solutions, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities;
- send you satisfaction surveys to better understand your uses and experiences with our products, solutions and Services;
- help diagnose problems with our servers, to manage our Services and to enhance our Services based on the usage pattern data we receive;
- keep business records (such as tax and accounting);
- protect our operations or those of any of our affiliates;
- protect our rights, privacy, safety or property, and/or that of our affiliates, you or others;
- comply with legal process;
- pursue available remedies or limit the damages that we may sustain; and
- respond to requests from public and government authorities.
4. DISCLOSURE OF INFORMATION
We may disclose information, including personal information, to any iDirect affiliates or nonaffiliated entities as set out below:
- Affiliates and Service Providers. We engage affiliates and service providers who may perform functions on our behalf, such as: provide quotes and other information; provide our products, solutions and the Services, hosting, content management, sales, marketing, analytics, general business support, customer service, training, installation and maintenance services, and fraud protection. These entities may have access to your personal information when needed to perform their functions.
- Business Transfer. In the event that we sell or buy any business or assets, we may disclose your personal information to the prospective buyer or seller of such business or assets.
- If one or more of the iDirect group of companies, or substantially all of its assets, are acquired, personal information held by it about its customers, suppliers and potential business contacts will be one of the transferred assets.
- Legal Obligations. We may disclose your personal information to: comply with any legal obligation; enforce or apply our terms and conditions and other agreements; or protect the rights, property or safety of iDirect, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- Anonymized/Aggregated Data. We may disclose anonymized or aggregated information about our customers for marketing, advertising, research or other purposes.
5. COOKIES AND TRACKING TECHNOLOGIES
As you use the Services, we and our service providers use cookies, JavaScript, log files, and other mechanisms to automatically collect and record information (including personal information) about your usage and browsing activities, and store it on our or our service providers’ server logs. We use this information to, for example: analyze and understand how users of our Services access, use, and interact with others through our Services; identify and resolve bugs and errors in our Services; and to assess secure, protect, optimize, and improve the performance of our Services. Depending on your jurisdiction, you may have certain choices about our use of cookies and tracking within the Services, as described in this section. We may also aggregate such information to analyze trends, administer our Services, and gather broad demographic information for aggregate uses.
If you are accessing our Services from the EEA or UK, more information regarding the information we collect through cookies and other tracking technologies and how we use that information can be found in our EEA/UK Cookie Policy.
Cookies. Cookies are text files that are placed on your computer or other mobile or handheld device (such as smartphones or tablets) when you visit certain pages on the internet. Cookies are used to “remember” when your computer or device accesses this website. Cookies are stored in your browser. The cookie will help the website, or another website, to recognize your device the next time you visit. Most cookies will not collect information that identifies you as a person and will instead collect more general information, such as how visitors arrive at and use our website. Cookies may, however, be used to create a profile of the visitor’s activities on the internet.
We may use both “session cookies” (which expire once you close your web browser) and “persistent cookies” (which stay on your device until you delete them) to provide you with a more personal and interactive experience with the Services. Persistent cookies can be removed by following your internet browser help file directions. We also use first-party cookies, those set by the website you are visiting and which can only be read by that website. In addition, we may use nonaffiliated cookies (also known as “third-party cookies”), those set by a different organization to the owner of the website you are visiting. For example, advertisers and other nonaffiliated entities may use their own cookies when you click on an advertisement or link on our Website or we might engage a nonaffiliated analytics company who will set their own cookie to perform this service. If you choose to disable cookies, some areas of the Services may not work properly so that we might not be able to provide you with our content or Services at all.
URLs. We use navigational data like Uniform Resource Locators (URLs) to gather information regarding the date and time of your visit and the solutions and information for which you searched and viewed.
IP Addresses. An “Internet Protocol address” or “IP address” is a number that is automatically assigned to your computer when you use the internet. In some cases, your IP address stays the same from browser session to browser session; but if you use a consumer internet service provider, your IP address probably varies from session to session. We, or our service providers, may track your IP address when you access the Services.
Analytics. We use tools operated by nonaffiliated companies, such as Google Analytics, to evaluate usage of our Services. These nonaffiliated analytics companies use cookies, and other tracking technologies to collect usage data about our Services to provide us with reports and metrics that help us to evaluate usage of our Services and improve them and to enhance performance and user experiences.
To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://policies.google.com/technologies/partner-sites. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Advertising. We work with nonaffiliated ad networks, analytics, marketing partners, and others (all together, “nonaffiliated ad companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on nonaffiliated websites. We and these nonaffiliated ad companies may use cookies, and other tools to collect browsing and activity information within our Services (as well as on nonaffiliated websites and services), as well as IP addresses, unique IDs, cookie and advertising IDs, and other online identifiers. We and these nonaffiliated ad companies use this information to provide you more relevant ads and content within our Services and on nonaffiliated websites, and to evaluate the success of such ads and content.
Nonaffiliated Entity Content. Some content or applications provided through our Services may be served by nonaffiliated entities. These entities may use technologies (such as cookies) to automatically collect information about you, including personal information, when you use the Services. They may collect information about your online activities over time and across different websites and other online services. They may also use persistent identifiers to track your internet usage beyond our Services. They may use this information to provide you with interest-based advertising or other targeted content. We do not knowingly provide these entities with information that personally identifies you. However, with sufficient data from other sources, such nonaffiliated entities may be able to personally identify you without our knowledge. We do not control these nonaffiliated entities’ tracking technologies or how they may be used. We are not responsible for either the content on an unaffiliated website or the privacy practices of an unaffiliated website operator, including those to which our Services link or that link to our Services.
6. YOUR CHOICES
You have certain choices regarding the personal information we collect about you. For example, you may:
- Opt out of promotional email communications. You may opt out of promotional emails by clicking on the unsubscribe link in the email. You may also opt out by emailing us at privacy@idirect.net and explaining that you would like to unsubscribe from our promotional emails.
- Opt out of interest-based advertising. We use non-affiliated providers such as Google to help us provide advertisements to you that are tailored to you based on interests that you have expressed on our Website or elsewhere (“interest-based ads”). Any advertisements served by Google, Inc., and affiliated companies may be controlled using cookies. These cookies allow Google to display ads based on your visits to this Site. Any tracking done by Google through cookies and other mechanisms is subject to Google’s own privacy policies. You may decide to disable Google cookies by visiting https://myadcenter.google.com/. You can visit Google’s My Ad Center to manage the Google ads you see and opt out of interest-based ads delivered by Google. You also may opt out of receiving interest-based ads from many non-affiliated ad networks, such as those provided by members of the Network Advertising Initiative (“NAI”), the Digital Advertising Alliance (“DAA”), and the European Interactive Digital Advertising Alliance (“EDAA”). For more information regarding interest-based ads by NAI, DAA, and EDAA members, including how to opt out of interest-based ads provided by NAI and DAA members, please visit their respective websites: optout.networkadvertising.org, optout.aboutads.info, and youronlinechoices.eu. Please note that opting out of participating ad networks does not mean that you will not see any advertisements; you will continue to receive advertisements on other websites and from companies that do not participate in the above programs. Even if you opt out of interest-based ads, you may still see ads based on factors such as your general location derived from your IP address, your browser type and recent, previous searches related to your current search.
Please note that even if you opt out of receiving marketing communications from us, we may still send you communications about your account or products, solutions or Services you have purchased or received from us, and we will still respond to your inquiries and requests for information.
7. RETENTION
We apply a general rule of keeping personal information only for as long as required to fulfill the purposes for which it was collected. In general, we retain your personal information for a period of time corresponding to a statute of limitation setting out the period during which legal claims may be filed in court. For example, we will retain your personal information during the statute of limitation period, to maintain an accurate record of your dealings with us or raise or defend claims in court. However, in some circumstances we may retain personal information for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority or other governmental entity having authority to make the request, for so long as required.
8. EXTERNAL LINKS AND FEATURES
This Notice does not apply to the practices of nonaffiliated entities that iDirect does not own or control or to individuals that iDirect does not employ or manage, such as consultants and contractors. The processing of personal information by nonaffiliated entities not controlled by us is governed by the privacy policies and procedures of those entities.
Nonaffiliated Websites. Our Website and Apps may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
9. SECURITY
The security of your personal information is important to us. We have implemented safeguards that aim to protect all information that we collect and retain, such as information (including personal information) stored on our servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, we encourage you to choose a strong password and to keep this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. We endeavor to provide secure communications but cannot guarantee the security of your data transmitted to our products, solutions or Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
10. CHILDREN’S INFORMATION
Our Services, including the Website, are not directed at users under the age of eighteen (18). We do not knowingly collect or maintain personal information from users we know are under 18 years old. If we become aware that we have collected personal information from a user under the age of 18 without verification of parental consent, we will take steps to remove such user’s information from our systems.
11. CHANGES TO THIS NOTICE
We may make changes to this Notice from time to time and will post any changes to this Notice on our website. If we make any material changes to this Notice, we will endeavor to provide you with reasonable notice about the changes, for instance by posting a prominent notice on our Website or through your email address we have on record. Where required by law, we will obtain your consent or give you the opportunity to opt out of such changes.
12. CONTACT US
If you have questions or concerns about our Notice or wish to exercise your rights, please contact us by email or by postal mail:
United States
ST Engineering iDirect, Inc. dba iDirect
Attn: Legal re: Privacy Notice
13861 Sunrise Valley Drive, Suite 300
Herndon, VA 20171 USA
Email: privacy@idirect.net
Europe
ST Engineering iDirect (Europe) CY NV
Attn: Legal re: Privacy Notice
Laarstraat 5, 9100 Sint-Niklaas, Belgium
Email: privacy@idirect.net
You may request a copy of this Notice by emailing privacy@idirect.net.
13. ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
This section of the Notice provides additional information for California residents and describes our information practices as required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (“CCPA”). Depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our privacy practices.
Scope
This section applies to information that we collect, use, disclose, and otherwise process that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”, as defined by the CCPA).
Personal information, as defined by the CCPA, does not include:
- Publicly available information, including information lawfully made available from federal, state, or local government records.
- Deidentified or aggregated information.
- Information otherwise excluded from the CCPA’s scope.
This California section of the Notice also does not apply to personal information we collect about California resident job applicants, independent contractors, or current or former full-time, part-time, or temporary employees or our staff, officers, or directors. Job applicants can review our applicable policy here.
Notice at Collection
The following subsections below, read together, are intended to comply with our obligations with respect to Notice at Collection under the CCPA: “Information That We Collect and Disclose for Business or Commercial Purposes”, “Retention”, “Purposes of Collection, Use, and Disclosure of Personal Information”, and “Sale or Sharing of Personal Information.”
Information That We Collect and Disclose for Business or Commercial Purposes
Depending on how you interact with us, we may collect the following categories of personal information (and have collected them in the prior 12 months):
| Category of Personal Information | Examples | Third Party Disclosures for Business or Commercial Purposes |
|---|---|---|
| Identifiers. | A real name, email address or other similar identifiers. |
|
| Personal information categories listed in the California Customer Records statute. | A name, signature, address, telephone number, current employer, or job title. Some personal information included in this category may overlap with other categories. |
|
| Commercial information. | Products, solutions or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
|
| Internet or other similar electronic network activity. | Browsing history, search history, information on a person’s interaction with a website, application, or advertisement. |
|
| Location data. | Physical location. |
|
| Professional or employment-related information. | Current job title. |
|
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you.
- Indirectly from you, through your use of our website.
- Operating systems and platforms and internet service providers.
- Advertising networks, social networks, and data analytics providers.
- Government entities.
Retention
For information regarding our retention practices related to your personal information, please see Section 7. Retention above.
Purposes of Collection, Use, and Disclosure of Personal Information
As further described in Section 3. Purposes for Collection and Section 4. Disclosures of Personal Information, we generally collect and otherwise process personal information for the following business or commercial purposes, and otherwise as directed or consented to by you:
- To communicate with you;
- To provide the Services and support;
- To plan and manage events;
- For marketing and advertising purposes;
- For customization and personalization;
- For auditing, reporting, and other internal operation purposes;
- For analytics and improvement;
- For testing, research, analysis, and product and solution development.
- In support of business transfers (e.g., if we are acquired by another company).
- As necessary or appropriate for security and to protect our rights, property or safety, or that of our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
Sale or Sharing of Personal Information
The CCPA defines a “sale” as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising.
While we do not disclose personal information to third parties in exchange for monetary compensation, we may be considered to be “selling” or “sharing” (as defined by the CCPA) personal information because we use third-party ad and analytics cookies on our website. We may “sell” or “share” identifiers (e.g., IP address, unique personal identifiers, and online identifiers) and internet or other electronic network activity information with data analytics providers, advertising networks, and social networks. We do so in order to improve and evaluate our advertising campaigns and better reach customers and prospective customers with more relevant ads and content.
We do not sell or share sensitive personal information, nor do we sell or share personal information about California residents who we know are younger than 18 years old, without opt-in consent.
Your Rights and Choices
The CCPA provides you with specific rights regarding your personal information, subject to certain exceptions. This section describes CCPA rights and explains how to exercise those rights. Note that these rights only apply to personal information we collect and process under this Notice as a “business” under the law. For personal information we process on behalf of our commercial clients in our capacity as a service provider, please submit your request directly to the client with whom you have a relationship, and we will provide reasonable assistance to that client as necessary to enable them to respond to your requests to exercise your privacy rights.
Know/Access: The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
Deletion: The right to the deletion of personal information that we have collected, subject to certain exceptions.
Correction: The right to correct inaccurate personal information that we maintain about you.
Opt-Out Rights: The right to opt out from iDirect selling or sharing your personal information. You may exercise your opt-out rights by managing your cookie preferences here.
Limit Certain Uses and Disclosures of Sensitive Personal Information: We do not collect, use, or disclose “Sensitive Personal Information,” as that term is defined under the CCPA, thus the right to limit certain uses and disclosures of sensitive personal information is not available to California residents.
- Right to Non-Discrimination: The right not to be subject to discriminatory treatment for exercising your rights under the CCPA.
Exercising Your Rights
To exercise the rights described above, please submit a request to us through one of the following methods:
- Email: privacy@idirect.net
- Webform: https://www.idirect.net/ccpa-request-webform/
- Toll-Free Number: 1-877-830-5754
- Mail: ST Engineering iDirect, Inc. dba iDirect, Office of the General Counsel, 13861 Sunrise Valley Dr, Suite 300, Herndon, VA 20171
Only you, or your authorized agent, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
A verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Initially, we will need your full name, email and company name.
- Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
Please note that we cannot fulfill your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. If we cannot verify your identity based on the information you provided, we may reach out to ask for additional verifying information. If we still cannot verify your identity after a good-faith attempt, we may deny your request.
Changes to the California Section
For information regarding our privacy notice revision practices, please see Section 11. Changes to this Notice above.
Contact Information
For information regarding our contact information, please see Section 12. Contact Us above.
14. ADDITIONAL PRIVACY INFORMATION FOR EEA AND UK RESIDENTS
Purposes and Legal Basis for Use of Your Personal Information
Whenever we use personal information, that use is justified by a ‘lawful ground’. The lawful grounds and purposes for using personal information are as follows:
Lawful ground – To perform a contract with you or take pre-contractual steps at your request:
- communicate with you and respond to your inquiries or requests (e.g., requested materials, a requested newsletter), including as part of the “Contact Us” feature on our Website;
- send administrative information to you, (e.g., information regarding the changes to our terms and conditions);
- provide you with customer service and customer support related to troubleshooting in connection with our products, solutions and Services;
- carry out our obligations and enforce our rights arising from contracts entered into between you and iDirect, including for billing and payment collection; and
- conduct registration, attendance for events and Services you have requested.
Lawful ground – Our legitimate interests:
- except when your consent is required (see below), send you marketing communications, including via email and SMS in compliance with applicable laws, that we believe may be of interest to you;
- present products, solutions and offers tailored to you;
- tailor your experiences with our Services to meet your special interests and needs;
- manage the planning of events and webinars, and other management-related purposes (contacting you about events, products, solutions and Services);
- engage in one of the following activities: data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities;
- send you satisfaction surveys to better understand your uses and experiences with our products, solutions and Services;
- help diagnose problems with our server, to manage our Website and to enhance our Website based on the usage pattern data we receive;
- protect our operations or those of any of our affiliates;
- protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
- pursue available remedies or limit the damages that we may sustain.
When the lawful ground is our legitimate interests, those interests are to process user data collected through our Services to conduct, develop, and grow our business activities with customers, users, and with others, and to improve our services and profitability, while limiting the use of personal information to those purposes that strictly support the conduct and development of our business as described in this Notice.
Lawful ground – Consent:
- in some cases applicable law requires us to obtain your consent to send you marketing communications, including via email and SMS, and in these cases, we rely on your consent to process your data for marketing purposes; and
- connecting you with event attendees.
Lawful ground – When we are required to comply with the laws of the UK or an EU member state:
- keep business records (such as tax and accounting);
- comply with legal process;
- respond to requests from public and government authorities; and
- protect privacy, safety or property, as and when specifically required by the laws of the UK or an EEA member state.
Transferring Your Personal Information
The personal information that we collect from you may be accessed in, or transferred to, and stored in United States, Canada, United Kingdom and Singapore, as well as EEA member states. The United States and Singapore do not benefit from a decision of the European Commission or the UK government stating that they provide adequate protection to personal information (except in specific circumstances not relevant here). The United Kingdom and Canada benefit from an adequacy decision of the European Commission finding that UK-specific Canadian law affords adequate protection to personal information. The personal information may be stored by iDirect or its service providers, or processed by staff operating outside the EEA or the UK who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of Services. We will take all steps reasonably necessary to ensure that your data is treated with an adequate level of protection in the jurisdictions in which we process it. Personal information transferred among iDirect and its affiliates will be made on the basis of an adequacy decision, or standard contractual clauses as approved by the European Commission or UK authority. Other personal information will be transferred under suitable safeguards, depending on the circumstances and the recipient, such as standard contractual clauses as approved by the European Commission or UK authority, or Binding Corporate Rules. A copy of such safeguards may be obtained by contacting privacy@idirect.net.
Your Rights
Subject to certain limitations and restrictions laid out in the EU GDPR/UK GDPR, you have the following rights:
- Right to access – you have the right to request access to and a copy of any of your personal information that we hold, and to obtain information about the processing of that information.
- Right to correct – we will take steps in accordance with applicable legislation to keep your personal information accurate, complete, and up to date. You are entitled to have any inadequate, incomplete, or incorrect personal information corrected (that is, rectified).
- Right to withdraw consent – in the event your personal information is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- Data portability – where we are relying (as the legal basis for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal information is processed by automated means, you have the right to receive all such personal information which you have provided us in a structured, commonly used, and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
- Right to erasure – you are entitled to have your personal information erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below), or where personal information is unlawfully processed.
- Right to restriction of processing – you have the right to restrict our processing of your personal information (that is, allow only its storage) where:
- you contest the accuracy of the personal information, until we have taken sufficient steps to correct or verify its accuracy;
- where the processing is unlawful but you do not want us to erase the personal information;
- where we no longer need your personal information for the purposes of the processing, but you require such personal information for the establishment, exercise, or defense of legal claims; or
- where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.
Where your personal information is subject to restriction, we will only process it with your consent or for the establishment, exercise, or defence of legal claims.
- Right to object to processing (including profiling) based on legitimate interest grounds – where we are relying upon legitimate interests to process personal information, you have the right to object to that processing based on grounds related to your personal situation. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or we need to process the personal information for the establishment, exercise, or defence of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
- Right to object to direct marketing (including profiling) – you have the right to object to our use of your personal information (including profiling) for direct marketing purposes, such as when we use your personal information to invite you to our promotional events.
You may opt out of receiving commercial emails from us by clicking on the opt-out or ‘unsubscribe’ link included in the marketing e-mails you receive.
You may also have a right to lodge a complaint with a supervisory authority or other regulatory agency of your habitual residence, place of work or place of alleged infringement, if you believe that we have violated any of the rights concerning personal information about you. A list of data protection supervisory authorities in the EU is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
Please note that certain Services will not be available if you withdraw your consent, or otherwise delete or object to our processing of certain personal information.
If you wish to exercise any of your rights, you may contact us with your request at privacy@idirect.net or as described in Section 12. Contact Us above. We will respond to your request in accordance with applicable law, and we will inform you if we do not intend to comply with your request.