SPi Global General Data Privacy/ Protection Policy Statement
SPi Global is committed to ensure protection of personal information of its employees, customers, clients, and stakeholders, pursuant to the provisions of applicable Data Privacy/Protection Regulation in its operations globally. The values of Integrity, Accountability, Malasakit, and Respect are strictly observed in the collection, processing, security, retention, and disposal, of any personal information entrusted to, and acquired by the company, during the course of its engagements.
SPi Global upholds the highest standard of work ethic, honesty, and exhibits transparency in any engagement which involves the collection, processing, security, retention, and disposal of personal information of the data subjects.
The employees, internal stakeholders, and business partners, are responsible in complying with all the information security controls and policies related to Data Privacy/Protection; and are accountable for any action, and all its corresponding outcomes, in protecting the personal data of data subjects.
The SPi Global value of malasakit is consistent with the care provided to employee / client information. Security threats, breaches, incidents, or any act which may lead to the violation of any of the provisions in the Global Data Privacy/Protection (and or its corresponding SPi Global information security policies and procedure) are reported to the Data Protection Office (email@example.com), to the supervising authority, and to the data subject, as applicable.
SPi Global respects and honors the Rights of the Data Subjects, as follows:
- The right to be informed; that a data processor and/or controller should secure consent when gathering information directly from the data subject;
- The right of access to their personal data;
- The right to have inaccurate personal data rectified or completed when incomplete;
- The right to data portability that allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability;
- The right to have personal data erased;
- The right to object to process personal data for the legal task, marketing purposes, scientific/historical research and statistics;
- The right to be informed relating to automated decision making and profiling; and
- The right to seek damages through a civil court against organizations that fail to protect their personal data.
Further, SPI Global is committed to continuously:
- Implement organizational and technical controls to ensure that personal data are not compromised in all stages of the data lifecycle
- Educate its employees about their responsibilities in adherence to the company’s policies and procedures relating to the protection of personal data; and provide awareness on the penalties resulting to personal data breach and non-compliance to the requirements of the Global Data Privacy/ Protection
- Continuously encourage its employees to report any observed data privacy control issues
It only takes a moment to familiarize yourself with our privacy practices, so please do. If you have questions, please contact us.
Integrity and Security
At SPi Global, we take the security of your personal information very seriously. When your personal data is stored on any company-owned device, we use computer systems with limited access housed in facilities using logical and physical security measures adherent to governing data privacy regulations and information security standards.
When assessing these periods SPi Global carefully examines the need to collect personal information at all and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection, unless a longer or different retention period is required by law.
Collection and Use of Personal Information
You are not required to provide the personal information that we have requested, but, if you decide not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.
It is also important to note that when you post on an SPi Global forum, chat room, or social networking service, any personal information and content you share will be visible to other users and can be read, collected, or used by them. You are solely responsible for any personal information you choose to share or submit in these channels. For example, if you list your name and email address in a forum posting, that information will be considered public, and will be accessible to a lot of people.
What information are collected and how we use the information
- The personal information we collect also allows us to keep you posted on SPi Global’s latest product and service announcements, software and solutions updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by contacting our Corporate Communications team.
- We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, as well as for loss prevention and anti-fraud purposes. Your personal information may also be used for account and network security purposes, including the protection of our services for the benefit of all customers. We limit our use of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests. In some transactions, we may also validate the information you provided with publicly accessible sources.
- We may use your personal information, including your date of birth, to verify your identity, assist with the identification of users, and to determine appropriate services. For example, we may use your date of birth to help us get a better understanding of the demographics of our applicants.
- When you provide information such as your name, email address, country of residence, company you represent, industry and details, you authorize and enable us to respond to a general/business inquiry made by you or on behalf of a company that you represent. If you wish to be contacted by telephone, we may also collect your work phone number.
- When you provide your resume and other personal details to apply online for a job at SPi Global, we may use this information throughout the company or our affiliates and subsidiaries to consider you for employment, or to respond to your inquiry. We may also keep the information for future consideration of any suitable job opportunity that may arise.
- You provide us information when subscribing and using any of our subscription services. This data may include your name, email address and the organization you represent. Our subscription center keeps track of your communication preferences (over email or phone) and areas of interest (such as receiving newsletters, thought leadership content and/or marketing collateral) that you may have either opted into or opted out of.
- E-mail Communications: If you are a recipient of our marketing communications, we will track whenever you receive, open, click a link, or share an e-mail you receive from SPi Global.
- From time to time, we may use your personal information to send important notices, such as communications about changes to our terms, conditions, and policies.
- We may also use your personal information for internal purposes such as auditing, data analysis, and research to improve our products, services, and customer communications.
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, or disclose non-personal information for any purpose. Here are some examples of non-personal information that we collect and how we may use it:
- We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where an SPi Global product or publicly available link is used so that we can better understand customer behavior and improve our products, services, and advertising.
- We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevance of results provided by our services. Except in limited instances to ensure the quality of our services over the Internet, such information will not be associated with your IP address.
- With your explicit consent, we may collect data about how you use your device and its applications to help app developers improve their apps.
If we do combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined. We might receive or validate information about you from other sources to ensure the accuracy and completeness of your profile.
Our websites, online services, interactive applications, email messages, and advertisements may use "cookies" and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited. These also facilitate and measure the effectiveness of advertisements and web searches.
Please know that we may gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.
We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. We may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on the SPi Global website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
Disclosure to Third Parties
At times SPi Global may make certain personal information available to strategic partners that work with SPi Global to provide products and services, or that help SPi Global market to customers. Personal information will only be shared by SPi Global to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.
We also share personal information with companies who provide services such as information processing, fulfilling customer orders, delivering services, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever SPi Global operates.
Legal Duty to Disclose
It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for SPi Global to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
Additionally, in the event of a reorganization, merger, or sale, we may transfer to the relevant third party any and all personal information we have collected.
The existence of Automated Decision-Making, Including Profiling
SPi Global does not make any decisions involving the use of algorithms or profiling that significantly affects you.
Access to Personal Information
You can help ensure that your contact information and preferences are accurate, complete, and up to date by contacting us directly. For other personal information we hold, we will provide you with access for any purpose – including requesting the correction of inaccurate data, or the deletion of the data if SPi Global is not required to retain it by law or for legitimate business purposes.
We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier.
Third Party Sites and Services
SPi Global websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties.
Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. For your protection, we encourage you to learn about the privacy practices of those third parties.
As a global company, we have several legal entities in different jurisdictions which are responsible for the personal information which they collect.
We abide by the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies.
We understand the importance of taking extra precautions to protect the privacy and safety of children using SPi Global products and services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to create or provide their own personal information, unless their parent provided verifiable consent. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible.
If at any time a parent needs to access, correct, or delete data associated with a child’s data previously provided to SPi Global, they may contact us directly.
Our Company-wide Commitment to Your Privacy
To make sure your personal information is secure, we communicate our privacy and security guidelines to SPi Global employees and strictly enforce privacy safeguards within the company.
Questions & Complaints
SPi Global responds to or resolves a privacy question or question about personal information received on priority. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
For more details on SPi Global’s Data Privacy/Protection Policy, contact the Data Privacy Officer directly via firstname.lastname@example.org