Preava Privacy Notice
Effective on: October 22nd, 2020
Last updated on: August 4th, 2021
Introduction
Preava, Inc. ("Preava", "we", "us", "our") takes the protection of personal data ("Personal Data") very seriously. Please read this privacy notice (the "Notice") to learn what we are doing with your Personal Data, how we protect it, and what privacy rights you may have under the European Union General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act of 2018 ("CCPA").
What Is Covered by this Privacy Notice?
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receive directly through our website(s);
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receive from our business partners; or
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process to promote our products and services.
What Is Not Covered in this Privacy Notice?
Application Personal Data
This Notice does not apply to the Personal Data received from our direct customers ("Customers") in our web-based software application (the "Application). Please see the Application Privacy Notice for more information.
Human Resources Personal Data
This Notice does not apply to the Personal Data of employees, job applicants, contractors, business owners, directors, and officers of Preava.
Information Which Does Not Constitute Personal Data
If we do not maintain information in a manner that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household, such information is not considered "Personal Data" and this Notice will not apply to our processing of that information.
Personal Data Processed in Business to Business Communications and Transactions
This Notice does not apply to Personal Data reflecting communications or transactions between us and you when you are acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency ("Your Entity") and when we are conducting due diligence regarding Your Entity or providing or receiving a product or service to or from Your Entity.
What Can You Find in this Notice?
- What Personal Data we collect about you and how we obtain it;
- The lawful bases for processing your Personal Data;
- For what purposes we use that Personal Data;
- How long we keep your Personal Data;
- With whom we share your Personal Data;
- Your rights about the Personal Data we collect about you and how you can exercise those rights;
- How we protect your Personal Data; and
- How to contact us.
Our Role with Respect to Your Personal Data
- Regarding the Personal Data of employees, job applicants, contractors, users of our website(s) generally or business contacts and prospects of Preava, we decide the purposes and means of processing, and consequently act as a data controller or "business".
- Regarding the Personal Data of individuals which we receive from our direct customers ("Customers") in our web-based software application (the "Application), we process Personal Data as "service providers" or data processors on behalf of our Customers, who use our Application to store and process Personal Data of themselves, their own customers, clients, employees, and others. Please see the Application Privacy Notice for more information. Where you give your data to one of our Customers or where we collect your Personal Data on their behalf, our Customer’s privacy notice, rather than this Notice, will apply to our processing of your Personal Data. If you have a direct relationship with one of our Customers, please contact them to exercise your privacy rights.
Lawful Bases for Processing
What Personal Data We Process and How We Obtain It
Personal Data We Collect, Process, or Store | How We Obtain It | |
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
You provide it directly to us when you: ask a question, fill a form, make a complaint, or comment about one of our products or services; use our live chat; sign up as a client; sign up for one of our events; use one of our services in person or by phone. Our customers (including their employees, contractors, and other representatives of their companies) provide it to us; you, as a representative of one of our customers, give it directly to us for the purposes of sales or customer support; you visit our websites and social media sites; you use our apps; we receive it from other companies within our corporate group; our vendors provide it to us; when a friend of yours or one of our business partners refers you to our services by providing your Personal Data to us; and |
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Special categories of Personal Data A name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information. Some Personal Data included in this category may overlap with other categories. |
You sign up as a client; you sign up for one of our events; you use one of our services in person or by phone; and you, as a representative of one of our customers, give it directly to us for the purposes of sales or customer support. |
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Commercial information Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
Our customers (including their employees, contractors, and other representatives of their companies) provide it to us; you, as a representative of one of our customers, give it directly to us for the purposes of sales or customer support; we receive it from other companies within our corporate group; our vendors provide it to us; when a friend of yours or one of our business partners refers you to our services by providing your Personal Data to us; and when we purchase lists of individuals who might be interested in becoming customers of ours. |
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Internet or other similar network activity Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement history. |
You provide it directly to us when asking a question, fill a form, making a complaint, or commenting about one of our products or services; you visit our websites and social media sites; you use our apps; we receive it from other companies within our corporate group; our vendors provide it to us; and when we purchase lists of individuals who might be interested in becoming customers of ours. |
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Geolocation data Physical location or movements. |
You use our apps. | |
Professional or employment-related information Current or past job history or performance evaluations, job title. |
You provide it directly to us when asking a question, fill a form, making a complaint, or commenting about one of our products or services; use our live chat; you sign up as a client; sign up for one of our events; you use one of our services in person or by phone; our customers (including their employees, contractors, and other representatives of their companies) provide it to us; you, as a representative of one of our customers, give it directly to us for the purposes of sales or customer support; you use our apps; we receive it from other companies within our corporate group; our vendors provide it to us; when a friend of yours or one of our business partners refers you to our services by providing your Personal Data to us; and when we purchase lists of individuals who might be interested in becoming customers of ours. |
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Inferences drawn from other Personal Data Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
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We will not collect additional categories of Personal Data without informing you.
Cookies
For What Purposes Do We Use Your Personal Data?
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providing you with information that you request from us;
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responding to your requests or questions;
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fulfilling legal obligations and enforce our rights;
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improving our websites;
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improving our products and service offerings; and
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sending you email marketing communications about our business which we think may interest you.
How Long We Keep Your Personal Data
When the purposes of processing are satisfied, we will delete the related Personal Data within six (6) months or upon receipt of a verified request.
Sharing Personal Data with Third Parties
- Identifiers
- Special categories of Personal Data
- Protected characteristics
- Commercial information
- Internet or other similar network activity
- Geolocation data
- Professional or employment-related information
- Inferences drawn from other Personal Data
- Infrastructure services providers
- Customer service providers
- Internet service providers
- Cloud service providers
- Office tools providers
- Payment processing providers
- Customer survey providers
- Email service providers
- Web analytics providers
- Enterprise open source solutions providers
- Project management tool providers
- Secure office messaging software providers
- Customer relationship management (CRM) providers
Other Disclosures of Your Personal Data
What Privacy Rights Do You Have?
Right to Know What Happens to Your Personal Data
Right to Know What Personal Data Preava Has About You
- The categories of your Personal Data that we process;
- The categories of sources for your Personal Data;
- Our purposes for processing your Personal Data;
- Where possible, the retention period for your Personal Data, or, if not possible, the criteria used to determine the retention period;
- The categories of third parties with whom we share your Personal Data;
- If we carry out automated decision-making, including profiling, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you;
- The specific pieces of Personal Data we process about you in an easily-sharable format;
- If we sold or disclosed your Personal Data for a business purpose, the categories of Personal Data and categories of recipients of that Personal Data for disclosure;
- If we rely on legitimate interests as a lawful basis to process your Personal Data, the specific legitimate interests; and
- The appropriate safeguards used to transfer Personal Data from the EU to a third country, if applicable.
Right to Change Your Personal Data
This is called the right to rectification. It gives you the right to ask us to correct without undue delay anything that you think is wrong with the Personal Data we have on file about you or your child, and to complete any incomplete Personal Data.
Right to Delete Your Personal Data
Right to Ask us to Change How We Process Your Personal Data
This is called the right to restrict processing. It is the right to ask us to only use or store your Personal Data for certain purposes. You have this right in certain instances, such as where you believe the data is inaccurate or the processing activity is unlawful.
Right to Ask Us to Stop Using Your Personal Data
Right to Port or Move Your Personal Data
- Move it;
- Copy it;
- Keep it for yourself; or
- Transfer it to another organization.
Right to Withdraw Your Consent
Right to Non-Discrimination
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Deny you goods or services;
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Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
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Provide you a different level or quality of goods or services; or
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Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Right to Lodge a Complaint with a Supervisory Authority
How Can You Exercise Your Privacy Rights?
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Contacting us by email at privacy@preava.com;
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Writing to us by postal mail at:Preava, Inc.Attn: Chief Privacy Officer22 Essex Way #8203Essex, VT 05451USA
Verification of Your Identity
Response Timing and Format of Our Responses
Privacy of Children
Data Integrity & Security
We are strongly committed to keeping your Personal Data safe. We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect your Personal Data from unauthorized processing. Unauthorized processing includes unauthorized access, exfiltration, theft, disclosure, alteration, or destruction. Some of those protection measures include encryption and redaction and we also have dedicated teams to look after information security and privacy.
Data Transfer Mechanisms
U.S. Regulatory Oversight
Preava is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
European Union Supervisory Authority Oversight
If you are a data subject whose Personal Data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union member states.
Changes to this Notice
If we make any material change to this Notice, we will post the revised Notice to this web page. We will also update the "Effective" date. By continuing to use our websites after we post any of these changes, you accept the modified Notice.
Contact Us
Preava, Inc.
Attn: Chief Privacy Officer
22 Essex Way, #8203
Essex, VT 05451
USA
European Union Representative
VeraSafe Ireland Ltd
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland
Data Protection Officer
We have appointed VeraSafe as our Data Protection Officer (DPO). While you may contact us directly, VeraSafe can also be contacted on matters related to the processing of Personal Data. VeraSafe’s contact details are:
VeraSafe
22 Essex Way, #8203
Essex, VT 05451
USA
Email: experts@verasafe.com
Web: https://www.verasafe.com/about-verasafe/contact-us/