Privacy Policy

 

Summary:

- We will only use your personal data in connection with the Services (e.g. to process payments or to verify your identity and account)

- We will never sell your personal data to third parties

- You can easily opt in and out of any marketing communication at any time

- Please use the contact form if you have any questions about this policy or the use of your personal data

 

Your privacy and trust are important to us. This policy explains how the System1 Group of companies (“System1,” “we”, “us” or “our”) collect, handle, store and protect personal information about you in the context of our Services. It also provides information about your rights and about how you can contact us if you have questions about how we handle your information.

System1 provides information solutions for professionals and our Services are generally not aimed at consumers or children.

This policy applies to individuals who use any website, application, product, software or service of ours that hyperlinks to this Policy (our “Services”).

Within our Services, there may be links to third-party websites or applications. We are not responsible for the content or privacy compliance of third party websites or applications. You should check those websites or applications for their privacy statements and terms that apply to them.

For some services we make decisions on how personal information is used in the context of a service (System1 is a controller of personal information in this case), and for other services we will only use personal information as instructed by you (System1 is a processor of personal information in this case). Below you can find more information on the cases in which System1 is a controller of personal information and information on how to contact us.

We collect personal information about you from your interactions with us and from certain third parties and other sources (such as the subscriber providing access to our Services or from publicly available sources where permissible).

 

We obtain personal information from you:

  • through your interactions with us and our Services, such as, when you purchase Subscription services, register as a User, register for our newsletter or a webinar, request information via our contact form or call us for support (please note that we may record or monitor our telephone calls or email communication for compliance and quality assurance purposes)
  • through your system/device and use of our Services. Our servers, logs and other technologies automatically collect system/device and usage information to help us administer, protect and improve our Services, analyze usage and improve users’ experience
  • through cookies and similar technologies included on our Services. More information relating to cookies, and how to control their use can be found below

We also collect personal information about you from third parties such as:

  • the person(s) arranging for you to access our Services (e.g., the subscriber to our Services) in order to set up a user account
  • publicly available sources such as public websites, open government databases or other data in the public domain, to help us maintain data accuracy and provide and enhance the Services

 

What types of personal information we collect:

The type of personal information we or our subcontractors collect depends on how you are interacting with us and which Services you are purchasing or using.

 

The personal information we collect consists of the following:

  • Name and contact data, such as, first and last name, email address, postal address, phone number, and other similar contact data
  • Account Credentials, such as, passwords and other security information for authentication and access
  • Payment information, such as, payment card number (credit or debit card), and the security code associated with your payment instrument, if you make a payment
  • Device information, such as, information about your device, (e.g. IP address, location or provider)
  • Usage information and browsing history, such as information about how you navigate within our Services, your past and current sessions, your browsing history and which elements of our Services you use the most

How we use personal information

We process personal information about you on the basis that it is:

  • necessary for the performance of a contract or Service request: where we have a contract for our Subscription Services with you, we will process your personal information in order to fulfil that contract
  • where you give us your consent: we only ask for your consent in relation to specific uses of personal information where we need to and, if we need it, we will collect it separately and make it clear that we are asking for consent
  • for compliance with a legal obligation (e.g., to respond to a court order or a regulator)•where we have a legitimate interest to do so (e.g. to set up and administer your account, provide technical support, verify your identity or to send you important account, Subscription or Service information, understand how customers and users use our services, market risks, trends or activities or to personalize your experience of our Services).

 

Marketing

We deliver marketing and event communications to you via the System1 Ad Ratings communication or the general System1 newsletter and will ask you to explicitly opt in to receive marketing from us via these channels.

If we send you a marketing communication it will include instructions on how to opt out of receiving these communications in the future.

Even if you opt out of receiving marketing communications by email, we may still send you Service communications or important transactional information related to your accounts and Subscriptions (for purposes such as providing customer support).

 

How we share personal information

We share personal information within the System1 group, with our business partners and third party service providers (such as HubSpot, Google Analytics, Hotjar or Recurly) as directed by you through the use of our Services. Our third-party service providers are not permitted to share or use personal information we make available to them for any purpose other than to provide services to us.

When we transfer personal information internationally, we put in place safeguards in accordance with applicable law (including Articles 44 to 50 of the EU General Data Protection Regulation).  If you would like to know more about our data transfer practices and obtain copies of any relevant safeguarding measures, please contact our Privacy Team using the contact form on our website.

 

How long we keep personal information

We retain your information in accordance with the following criteria:

  • the length of time necessary to fulfill the purposes we collected it for
  • when you or the subscriber providing for your access to our Services cease to use our Services
  • the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations
  • any limitation periods within which claims might be made
  • any retention periods prescribed by law or recommended by regulators, professional bodies or associations
  • the existence of any relevant proceeding

 

Data security

Please protect sensitive data such as payment information at all times throughout your online transaction. Make sure that nobody can see over your shoulder when typing in personal information and close your browser when you have finished. System1 and its third party suppliers have used their reasonable endeavors to ensure that access to information provided and the payments you make whilst using this site are secure. We work to protect the security of your information during transmission. The site is secured using a SSL Web Server Certificate to offer you secure communications by automatically encrypting all data when it is entered.

You should be aware that the computer that you use to attach to the online-payments system (via a web browser) must also be secure, and include the latest operating system, software and anti-virus updates. The use of a shared computer to connect to the online-payments system could increase the risk that others will see your sensitive information.

 

Your rights

You may have rights under European and other laws to access your personal information and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information.

To exercise your rights, please contact us via the contact form. To opt out of marketing communication, just use the unsubscribe function in the email.

In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. Excessive requests may be subject to an administrative fee.

 

Cookies

Our websites and applications use cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small data file placed on your device which makes your use more enjoyable and allows us to improve our services.

Below is a list of the cookies we use:

  • Absolutely necessary cookies: These cookies are essential to enable you to move around a website and use its features. Without these cookies, Services you have asked for, like adding items to an online shopping cart, cannot be provided.
  • Performance cookies: These cookies collect information about how you use our websites. Information collected includes, for example, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These cookies only collect information in an aggregated format. Performance cookies are used to improve the user-friendliness of a website and enhance your experience.
  • Functionality cookies: These cookies allow the website to remember choices you make (such as your username or ID, language preference, or the area or region you are in) and provide enhanced, more personal features.

Targeting and advertising cookies: These cookies track browsing habits and are used to deliver targeted (interest-based) advertising. They are also used to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns. They remember that you have visited a website and this information is shared with other organizations, such as advertisers.

Lists of specific cookies can be found on the following websites:

 

Additionally we also use:

Web server & application logs: Our servers automatically collect certain information to help us administer and protect the Services, analyze usage, and improve users’ experience. The information collected includes:

  • IP address and browser type
  • Device information including Unique Device Identifier (UDID), MAC address, Identifier For Advertisers (IFA), and similar identifiers we or others may assign
  • Device operating system and other technical facts
  • The city, state, and country from which you access our website
  • Pages visited on our website and content viewed, stored, and services purchased
  • Information or text entered
  • Links and buttons clicked
  • URLs visited before and after you use our Services

 

System1 might use usage data collected for the purposes of detecting and preventing breaches of the System1’s network security, the law or any applicable T& Cs, support, capacity planning and the operation and improvement of System1’s Services.

 

Managing cookies

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of our site.

 

How to contact us

If you have any questions, comments, complaints or suggestions in relation to data protection or this policy, or any other concerns about the way in which we process information about you, please contact us via our contact form.

Filing a Complaint: If you are dissatisfied with how System1 manages your personal information, you can lodge a complaint with a privacy supervisory authority. In the European Economic Area, the relevant supervisory authority is the one in the country or territory where you are resident, you work or where the infringement took place.

 

Updates to this policy

This policy may be subject to updates. Any material future changes or additions to the processing of personal information as described in this policy affecting you will be communicated to you through an appropriate channel. For example, we may place a prominent notice on a product site or email you to let you know of an update in this policy. 

 

 

30th October 2018