WEBSITE PRIVACY PRACTICES
The following terms apply to users of our Website.
COLLECTION – WEBSITE
How we collect your personal information depends upon how you use and interact with our Website. Some information is provided directly by you, while other information may be collected through automated technologies.
Legal Basis for Collection. When accessing our Website, we collect personal information from you where 1) we have your consent, 2) where your personal information is necessary for us to provide a service (for example, when you register for a webinar), or 3) where we have a legitimate interest to process your information and that legitimate interest is not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to process your personal information, or to process your personal information in order to exercise, establish or defend legal claims.
Website Access. More specifically, we may collect information when you provide it directly to us though the Website in webforms such as webinar registration forms or when you download white papers, articles or other collateral. The type of information collected on these forms includes the following:
Website Information Collection
We may collect the following types of information from you:
- First Name / Last Name
- Email Address
- Work Location
- Job Title
- Log-in credentials
Collected from Third Parties. We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide information about products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. Examples of the types of personal information that may be collected from external sources include name, business contact details such as email, phone number, and job title.
Do Not Track Requests. Lockpath does not process or respond to “Do Not Track” signals from your browser or other mechanisms that enable choice regarding the collection of personal information about your online activities over time and across third-party websites or online services.
HOW WE USE PERSONAL INFORMATION – Website
We use personal information collected from the Website to respond to requests for information, including marketing and advertising communications, and to continue developing and improving the Website.
When you make requests on the Website We use information collected from on the Website to respond to visitors’ requests. Lockpath does not sell, rent, lease, trade or share visitors' personal information other than as outlined in this Privacy Statement. When you provide us with your personal information or otherwise choose to sign up to receive email communications from us, we will use that information to send those communications to you. Individuals may "opt-out" of receiving e-mail communications through selections available on e-mails received.
Webinar Participants. For participants of our web seminars (“webinars”), the only personal information we share is webinar registration information and it is only shared with our webinar presenters for the limited purpose of providing this service.
Interest Based Ads. Some information, like name and email, are collected for advertising purposes. This means you might see an advertisement from us on other sites you visit. Sometimes we allow third party advertising companies and ad networks to use automatic data collection technologies to collect similar information about you for purposes of providing you with interest-based ads. Interest-based ads are helpful because they are more likely to be tailored to your particular interests. They are also more likely to help you discover new services that are actually relevant to you and your interests. Also, if interest-based tracking is enabled, you likely will not see the same ads over and over because the number of times you see a particular interest-based ad is usually limited. By opting-out of interest-based ads, you lose all of these benefits.
Data Retention. Where Lockpath serves as the controller of the data, such as where we use personal information for our own independent business purpose, we will retain your information in accordance with our data retention practices as follows: We will retain your information for the period of time that it serves a purpose compatible with the purpose for which it was originally collected or subsequently authorized and in accordance with applicable law. For example, we will retain your information for as long as your account is active, as necessary to comply with our legal obligations and rights, to resolve disputes, and to enforce our agreements.
HOW WE SHARE INFORMATION – Website
Where we share personal information with third parties, we do so as set forth below. Any information we collect will never be sold, rented, traded, shared or leased other than as outlined in this Privacy Statement.
Service Providers and Analytics. Lockpath contracts with select third parties to provide us with Web-based services that include e-mail delivery and content streaming; these services may collect certain visitor data and click through data, including IP address, referring page, pages visited on our Website and whether you opened and email, and clicked on any content within that email. These companies are authorized to use directly identifying data, for example, e-mail addresses, only as necessary to provide for the service requested, in accordance with Lockpath’s privacy practices and pursuant to written instructions.
YOUR RIGHTS – Website
Lockpath acknowledges that you may have the right to access your personal information. Lockpath has partnered with NAVEX Global, its affiliated owner, to facilitate your inquiries as applicable.
Rights provided under the Privacy Shield Frameworks to personal information transferred from European Union (EU) member countries and Switzerland to the United States. Lockpath respects your control over your information and, upon request, we will confirm whether we hold or are processing information that we have collected from you. You also have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information or request that we no longer use it. Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation. In order to make such a request of us, please use this web form, powered by NAVEX Global. NAVEX Global and Lockpath will respond to and manage your request with respect to the personal information Lockpath holds.
Software Platform Users Note. Please note that where personal information is collected within the software solutions we offer, we do so on behalf of customer organizations and those customer organizations manage the data in accordance with their own internal policies and procedures. Any questions related to how that customer organization may process, use or share your information should be directed to that customer organization by contacting them directly. Unless otherwise prohibited by law, we will honor and support any instructions they provide us with respect to your personal information.
European Economic Area, Switzerland or United Kingdom Citizen Rights. Individuals who reside in the European Economic Area (EEA), including Switzerland and the United Kingdom (UK) have additional rights reserved under the General Data Protection Regulation (GDPR), the UK Data Protection Act and/or ePrivacy Directive, as applicable. This section details those additional rights and information on how to exercise them:
To make a request please use this web form, powered by NAVEX Global or email us at firstname.lastname@example.org with “Personal Information Request” in the subject line, and provide us with full details in relation to your request, including your contact information and any other detail you feel is relevant. Lockpath and NAVEX Global will provide a response to an access request within 30 days of receiving such request with respect to the personal information Lockpath holds or if we cannot, we will notify you and provide you with the reason for the delay.
California Citizen Rights. If you are a California-based consumer, as that term is defined under California law, this section shall apply in addition to all other applicable rights and information contained in this privacy statement. We collect, use and disclose the categories of personal information from the sources identified in this privacy statement. Our business purposes for such collection, use and disclosure, along with any categories of third party partners, are identified in this privacy statement. Individuals who reside in the state of California have additional rights reserved under the California Consumer Privacy Act and the California Shine the Light law:
- You have the right to request that we provide you with the categories of personal information and the specific pieces of personal information we have collected and store about you.
- You have the right to request that we delete personal information we, or our service providers, store about you.
- If you elect to exercise any rights under this section of our Privacy Statement, we will not discriminate or retaliate against you.
- We do not sell personal information.
- To exercise your rights as a California consumer, please use this web form, powered by NAVEX Global or call the NAVEX Global toll-free line at +1 844-842-0916. NAVEX Global and Lockpath will respond to and manage your request with respect to the personal information Lockpath holds. Also, be sure to check this policy for updates as we will review it at least every 12 months and make updates as necessary.
Identity Verification Requirement. We are required by law to verify that any request submitted was made by someone with the legal right to access the data. Therefore, prior to accessing or divulging any information pursuant to a data subject access request, we may request that you provide us with additional information in order for us to verify your identity and legal authority.
Under certain circumstances we may not be able to fulfill your request, such as where doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort; in any event, we will respond to your request within a reasonable time frame and as required by law, and provide you an explanation.