Effective date of current Policy: November 20, 2018 At EUGEN, we are committed to protecting your privacy. We want you to feel secure that your personal data are in good hands. EUGEN protects your personal data in accordance with applicable laws and our data privacy policies.
What information do we collect about you?
- We may collect the following types of Personal Information from you through this Website: name, title, contact details including e-mail address, and telephone numbers.
- On some pages, you may opt to provide us information about yourself for example if you are interested in (a) an employment opportunity; or (b) having EUGEN participate at your event.
- EUGEN may request that you voluntarily participate in a survey or poll such as feedback on website content or services. Your responses will be anonymous unless you opt in to being contacted by email to provide further information regarding the survey.
- In order to improve the design and content of our Website, to enable us to better personalize your user experience, and for other purposes outlined in this Policy, we may collect certain technical information about our visitors when you visit our Website pages, such as the IP address or the type of browser you are using, the type of operating system you are using, the domain name of your Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
- We may receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access third-party services, such as Linkedin, to login to the Services or to share information about your experience with EUGEN, we may collect information from these services.
For which purposes do we use your personal data?
- To provide products, Services, and information requested: We use your Personal Information to enable you to receive access to our products and services on-line, obtain information about our products and services and receive updates, participate in surveys or questionnaires posted on our Website, provide you with opportunities to learn about our other products, programs, or services that we believe may be of interest to you, and to enable us to respond to your requests.
- To market our products and Services: Our use of Personal Information may also include for purposes of providing you with materials about offers, products, and Services that may be of interest, including new content or Services. EUGEN may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law.
- For marketing purposes: Individuals who provide us with Personal Information, or whose Personal Information we obtain from third parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on EUGEN’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. In some cases, we may only contact you with your permission and we always offer the option to decline these communications at no cost to the individual by following the instructions below.
Do we share your information?
We may share your Personal Information under certain circumstances:
- Vendors and Service Providers: We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) customer service activities; and (v) in connection with the provision of the Site. EUGEN has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Business Partners: EUGEN may share Personal Information with our business partners, affiliates, and for our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with EUGEN’s. EUGEN requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it by any mean or for any purpose other than the means and purpose for which we provided it to them.
- Marketing, Interest-Based Advertising, and Third-Party Marketing: Through our Services, EUGEN may allow third party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-EUGEN related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. Subject to applicable law, we may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable, or otherwise of interest to you. If you prefer that we do not share your Personal Information with third party advertising partners, you may opt-out of such sharing at no cost by following the instructions below.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures): We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce EUGEN policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
- Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. Should such an event occur, EUGEN will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Policy in effect at the time such Personal Information was collected and will comply with any legal or regulatory additional requirements applicable to those transfers.
We do not share personally identifiable information with unrelated third parties who are not covered by this privacy statement without your prior permission, except to the extent reasonably necessary to: (i) correct technical problems and malfunctions; (ii) protect the security and integrity of our Website; (iii) protect our rights, interests and property and the rights, interests and property of others; (iv) comply with laws or to respond to judicial process; or (v) provide information to law enforcement agencies or for an investigation of a matter as applicable, or otherwise as required or permitted by law.
What about data security?
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
- provide access to our content: for example, allow you to personalize your experience by keeping you logged in, accessing information, products, and services relevant to your areas of interest,
- show adverts that are more relevant to you: for example, with your consent, we use tracking technologies to remember content that has interested you and remember content that has interested you. Cookies will also help limit the number of times that you see an ad, measure the effectiveness of advertising campaigns and help us and others track whether ads have been properly displayed so we can pay for this. We also allow other organizations to use tracking technologies for these advertising purposes too].
- prevent duplication: for example, when voting or participating in surveys.
- Pixel tags/Web beacons: A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you. You can also exercise the right to discontinue marketing communications to you, or to have your personal data removed from our customer relationship databases at any time by contacting us. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again
Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Rights of access, rectification, and erasure
You may inquire as to whether EUGEN is processing Personal Information about you, request access to Personal Information, and ask that we limit, restrict, port, correct, amend, or delete your Personal Information. Where otherwise permitted by applicable law, you may send us an e-mail or use any of the methods set out in this Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by EUGEN. Such requests will be processed in line with local laws. Although EUGEN makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which EUGEN is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If EUGEN determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, EUGEN will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information
The information you provide to us may be archived or stored periodically by us according to backup processes and will only be retained for as long as is required for the purposes for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Other third party websites
Our Website may contain links to other third party websites. You should carefully review the privacy policies and practices of other websites, as we cannot control or be responsible for privacy policies or practices of third-party websites that are not EUGEN’s Websites. For links to other EUGEN’s Websites, please review the privacy terms on those sites as well, as they may differ from those on this Website.
We would be pleased to send you information about products and services of ours and other companies in our group which may be of interest to you. If you have consented to receive marketing, you may opt out at a later date.
Notification of changes
Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the processing of Personal Information is otherwise required by law or contract, we will endeavor to comply with the law or contract.
How to contact us
If you wish to access, correct, update, request removal of or exercise your rights in relation to any of your information you provided to us or if you have any questions regarding this statement or would like more information on our privacy practices, please contact us at firstname.lastname@example.org