Privacy Policy and Privacy Notice

This privacy policy and privacy notice (“Privacy Policy”) applies to the various websites and cloud-based services owned and operated by OpenSecure, LLC, and its divisions, affiliates and subsidiaries (collectively “OpenSecure” or “We”), provided that where a service or affiliate publishes a privacy notice that is materially different from this notice, the other notice shall apply while interacting with such other affiliate or service.

 

OpenSecure places the highest priority on protecting the privacy of its registered users (“Users”) and the business entities that such Users represent (“Customers”), as well as others who access these websites and services (“Visitors”). OpenSecure websites and services are designed for adult Users and Visitors and are not to be used by anyone under 18. This Privacy Policy describes how OpenSecure collects, uses, shares and secures the personal information you provide when you access these websites and services or that OpenSecure receives or obtains about you. This Privacy Policy should be read in conjunction with any agreements between Customer and OpenSecure (the “Agreements”) that apply to the websites and services and with any other documents or guides that are provided from time to time in relation to the websites and services. This Privacy Policy and Privacy Notice pertains only to your personal data, so please review your contracts with OpenSecure to understand how other data is handled.

 

OpenSecure does not sell, trade, rent or share User or Visitor personal data to third parties for their commercial purposes unless you instruct us to do so, such as processing transactions with third parties via OpenSecure services or integrations you instruct us to enable with third parties.

 

Collection and Use of Information by OpenSecure

 

User Information

 

Users and Visitors communicate and exchange information (“User Information”) with OpenSecure and other Users in connection with their business relationship with OpenSecure and our websites and services. User Information may also be collected through email and other correspondence with OpenSecure, as well as with third parties or by any other means in connection with providing a service to a User, Customer or Visitor. User Information may include, without limitation, User ID, first and last name, email address, business phone numbers, and country. We also may collect other business information, such as invoice and payment information or tax ID numbers, in connection with specific services.

 

We will not sell your personal data to third parties or share or trade it with them for promotional purposes without your consent. We will share your personal data with third parties only in the ways that are described in this Privacy Policy.

 

OpenSecure and third-party service providers may use the personal data to:

 

a. perform the services or in connection with the operation of the services;

 

b. monitor and analyze system activity, including how the system is used and the volume and frequency of access, so as to improve the system and services;

 

c. contact you regarding your inquiries, your use of the system, or changes to the system or services and to otherwise operate the system;

 

d. comply with any applicable law or other info or regulatory requirements to respond to a request or subpoena by a government, regulatory or judicial authority where necessary in connection with a dispute, actual or potential litigation, other info process or an internal or external audit, or where otherwise necessary to protect the interests of OpenSecure, third-party service providers or other participants in the system;

 

e. supplement your personal data with third-party sources for background verification;

 

f. take appropriate actions when you ask a question, request support, register for an event or conference, request access to various thought leadership assets such as white papers, reports, case studies and so on, or participate in an online survey;

 

g. disclose to a Customer the activities of its authorized Users, which includes providing User Information and other information collected by OpenSecure to the Customer; and

 

h. gather information that does not identify specific Users or Visitors (collectively, “Aggregate Data”) from User Information, data, cookies and other information collected on OpenSecure’s websites and use such Aggregate Data for internal and/or commercial purposes.

 

With your consent, OpenSecure may use your personal data to market the products and services of OpenSecure and third-party service providers to Users and Visitors through the use of post/mail, fax or email. Please note that if OpenSecure sends marketing materials to you, you have the right to control your marketing preferences. For example, OpenSecure will include a working unsubscribe link on marketing emails so you can unsubscribe. You may review other options to control your marketing preferences in the Opting Out of Marketing Communications section of this Privacy Policy.

 

OpenSecure will also send you service-related email announcements on rare occasions when it is necessary to do so. For instance, if a service is temporarily interrupted for maintenance, We might send you an email. You do not have an option to opt out of these emails, but they are not promotional in nature.

In addition, any third party offering a service directly to your company in connection with our Services or on our Websites (including, without limitation, live chat service providers, email service providers and recruiting platforms) may use your personal data to: (a) provide the Services; (b) contact you regarding your inquiries; and (c) market its products and services to your company through use of post, fax or email. If you do not want us to share your personal data with these companies, contact us at info@opensecure.co.

 

Visitor Data

 

When a User or Visitor accesses OpenSecure websites and services, OpenSecure collects, records and retains data about such usage, including but not limited to the User’s or Visitor’s domain name and internet protocol (IP) address, the name of the webpage from which each User or Visitor entered an OpenSecure website or service, the locations each User visits within OpenSecure, and the amount of time spent on each page (collectively, “Data”). OpenSecure uses this Data to determine the demographics of Users and Visitors, analyze trends and add to third parties’ aggregate statistics and general information about OpenSecure.

 

User and Visitor Information Supplementation

 

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 input with information We already have about you. This helps OpenSecure update, expand and analyze our records, identify new customers and provide products and services that may be of interest to you. If you give 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 obtained from public sources or purchased from third parties and combined with information We already have about Users and Visitors may include:

 

a. purchased marketing data about our Customers from third parties that is combined with information We already have about you to create more tailored advertising and products, and

 

b. human resource information and basic business contact information when candidates are presented through recruitment agencies and when We use Salesforce.co to work on business contact leads.

 

Integrated or Linked Third-Party Services

 

Many of the services that OpenSecure operates are “networks” that connect various parties that wish to do business with each other. In many of these circumstances, both OpenSecure and other Users or third parties whom you participate with in the network through our services will be independently responsible for maintaining personal information about Users and Visitors. If you are a customer or employee of one of our Customers and would no longer like to be contacted by OpenSecure, please contact the Customer that you interact with directly. OpenSecure may have no direct relationship with the individuals whose personal data We receive through these networks. An individual who seeks access or who seeks to correct, amend or delete inaccurate data should direct his or her query to the Customer (the data controller) in addition to following the procedures in this Privacy Policy. OpenSecure is not responsible for information or data in the possession of these third parties, regardless of how such data was obtained. Please consult the third parties’ privacy policies to learn how they may use or disclose your information. You may be contacted directly by these third parties.

 

Aggregate or other information not identifiable with any individual may be used or disclosed for other purposes and to other parties as deemed appropriate by OpenSecure, subject to any obligations of confidentiality under the Agreement(s) and applicable laws.

 

Some of our webpages may utilize framing techniques to serve content from our partners while preserving the look and feel of our websites and services. Please be aware that you are providing your personal information to these third parties subject to their applicable terms and conditions and not to OpenSecure.

 

OpenSecure also provides links to other websites maintained by third parties unrelated to OpenSecure. Please be aware that if you link to a third-party website, that site is not subject to OpenSecure’s Privacy Policy and OpenSecure has no control over the use of information disclosed on such sites. OpenSecure is not responsible for the privacy practices or content of such other sites. OpenSecure encourages its Users and Visitors to be aware when they leave the OpenSecure websites and services and suggests that Users and Visitors read the privacy policies of each site visited.

 

Our websites and services may include social media features, such as the Facebook “Like” button, and widgets, such as the “Share This” button and interactive mini-programs. These features may collect your IP address and the webpage you are visiting, and they may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our websites. Your interactions with these features are governed by the privacy policy of the company providing them.

 

Disclosure of Personal Data to Third Parties

 

In certain situations, OpenSecure may be required to disclose personal data in response to lawful requests by public authorities. This may involve national security or law enforcement requirements, for example. OpenSecure, third-party service providers and partners may disclose your personal data to:

 

a. any affiliate, agent or subcontractor of OpenSecure and/or its third-party service providers, as applicable, including companies that provide technical services to OpenSecure such as data processing companies, since these companies are authorized to use your personal data only as necessary to provide these services to OpenSecure;

 

b. any affiliate, agent or subcontractor of OpenSecure and/or its third-party service providers, as applicable, for the purposes of operating the system and, with your consent, for the marketing and/or provision of third-party services because, as stated above, all of the third parties offering services through the system may receive your personal data;

 

c. any affiliate, agent, subcontractor or adviser of OpenSecure and/or its third-party service providers, or a government, regulatory or judicial authority, as applicable, in connection with an internal or external audit or examination, a dispute or actual or possible litigation, a request, subpoena or similar info process, or where disclosure is otherwise permitted or required by law;

 

d. any affiliate, agent, subcontractor or adviser of OpenSecure and/or its third-party service providers, Customers, or a government, regulatory or judicial authority, as applicable, where necessary to protect the interests of OpenSecure, the public or other participants in the System, such as in the event of suspected fraud or ilinfo activity; and

 

e. anyone to whom you authorize OpenSecure to give your personal data, including parties you have authorized to access your personal data in connection with your activities as a User or Visitor.

 

In the event that OpenSecure or any of its assets are acquired or become the subject of a merger or acquisition, then your personal data may be transferred with the business or disclosed to potential acquirers or other authorized parties involved in such transaction but shall not otherwise be sold or rented to any third party. You will be notified of this change as described below in “Changes to this Policy.”

 

Tracking and Targeting Technologies

 

OpenSecure uses technologies such as cookies, beacons, tags and scripts directly or through our partners, which may include marketing partners, affiliates, analytics providers and/or service providers such as an online customer support provider. These technologies are used in analyzing trends, administering the websites and services, tracking movements around the sites and gathering demographic information about Users and Visitors. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

 

We use cookies to help personalize your online experience. Users and Visitors can control the use of cookies through their individual web browsers (these reference sites can provide more information about how to interact with your web browser http://optout.aboutads.info/ or http://www.youronlinechoices.eu/). There may also be tools within our websites that alert you to the cookies We use and let you make selections about which ones you want to use. You must accept essential cookies, and if you use tools to reject them you may still be able to use our websites and services but your ability to use some features or areas of our sites or services may be limited. If you reject optional cookies, certain features or services may be unavailable to you.

 

As is true of most websites, We use a third-party tracking utility partner to gather certain information automatically and store it in log files. This information includes an individual’s IP address, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information, which does not identify individual Users, to analyze trends, administer the websites, track users’ movements around our websites and gather demographic information about our user base.

 

We use local shared objects (LSOs), including HTML5, to store content information and preferences. Limited to services on Inttra. Third parties with whom We partner to provide certain features on our websites or to display advertising based upon your web browsing activity use LSOs such as HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

 

Limited to services on inttra.co, we partner with a third party to either display advertising on our websites or manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on our websites and other sites to provide you with advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may control these settings in your web browser. The following third-party websites may assist you in doing so: http://optout.aboutads.info/ or http://www.youronlinechoices.eu/. Please note that this does not opt you out of being served ads. You receive non-targeted ads after opting out.

 

Bulletin Boards, Chat Rooms and Forums

 

If you use a bulletin board, chat room, forum or other chat tool on our websites, you should be aware that any personally identifiable information you submit there can be read, collected or used by other users of these forums and could be used to send you unsolicited messages. OpenSecure is not responsible for the personally identifiable information you choose to submit in the forums. You are also responsible for using our forums in a manner consistent with the Terms of Use, Acceptable Use Policy, Privacy Policy and/or other terms and conditions set forth on the relevant forum’s website. All forums are hosted by a third-party service provider of OpenSecure. To request removal of your personally identifiable information from our blog or community forum, contact us at info@opensecure.co. In some cases, We may not be able to remove your personally identifiable information. In those situations We will let you know if We are unable to do so and why.

 

Security

 

OpenSecure and its third-party providers have implemented extensive security measures to help protect against the risk of loss, misuse and alteration of any information under OpenSecure’s control. These measures include using encryption, limiting employee access and using industry-standard controls such as firewalls and secure environments for personally identifiable information.

 

Additionally, in order to protect the security and integrity of the proprietary and confidential information of OpenSecure’s Customers and Users who interact on the non-public portion of OpenSecure’s secure collaboration network, OpenSecure has taken the following actions, among many others, to ensure that OpenSecure meets the strict security needs of these individuals.

 

OpenSecure has adopted and enforces a Corporate Security Policy to protect all proprietary and confidential information of OpenSecure’s Customer. The Corporate Security Policy addresses information classification, information security procedures (electronic and hardcopy information), limited disclosure procedures, physical facility access, and general security awareness and enforcement. OpenSecure has developed and adheres to strict security policies and guidelines with all OpenSecure’s third-party data hosting facilities providers.

 

OpenSecure has deployed industry-standard Customer authentication and User verification procedures to limit access to Customer information to only those participants that our Customers authorize.

 

Notwithstanding OpenSecure’s extensive efforts, such security measures may not prevent all loss, misuse or alteration of information disclosed on the websites.

 

Notice, Access and Choice

 

Users and Visitors can access their User Information and other appropriate personally identifiable information collected by OpenSecure by contacting OpenSecure support as set forth in the Contact section of the websites. If a User believes there are factual errors in such information or would like to update it, the individual may contact OpenSecure Customer Support or the Customer’s Company Administrator and detail the inaccurate information. OpenSecure and/or the Customer’s Company Administrator will verify and correct any factual errors within 30 days. Users have the right to request that their User Information and other personally identifiable information collected by OpenSecure be deleted and can do so by contacting OpenSecure Customer Support. Information will be deleted within 30 days. If applicable law requires a quicker response, We will act within that timeframe.

 

We will retain your information for as long as your account is active or as needed to provide you with services. If you wish to cancel your account or request that We no longer use your information to provide you with services, contact us at info@opensecure.co. We will retain and use your information as necessary to comply with our info obligations, resolve disputes and enforce our Agreements.

 

OpenSecure intends to comply with all applicable data protection laws. If you believe you have additional rights that are not listed here, please contact us.

Where We rely on your consent to process your personal data, you may withdraw your consent for the processing of your personal data at any time. However, if you do so, OpenSecure may not be able to provide certain services to you or give you access to parts of the websites.

 

Opting Out of Marketing Communications

 

Users and Visitors may choose whether to receive marketing communications relating to OpenSecure at the time of registration. If a User or Visitor subsequently does not want to receive information about special offers available through OpenSecure or if a User or Visitor no longer wishes to receive OpenSecure’s newsletter and promotional communications, Users and Visitors may opt out of receiving them by following the instructions included in each newsletter or communication or by contacting OpenSecure.

 

Individuals can also unsubscribe from OpenSecure marketing communications by visiting www.OpenSecure.co/unsubscribe. If you wish to have your information removed from our contact database, please visit www.OpenSecure.co/userdeletion.

 

Modification of this Privacy Policy

 

We may modify this Privacy Policy at any time, and We encourage you to periodically review this Privacy Policy. If We make material changes to this Privacy Policy, We will provide notification by email or by means of a notice on our homepage prior to the change becoming effective. Changes to the Privacy Policy will be effective upon posting. We will also provide notification by email or by means of a notice on our homepage in the event of a merger, change in corporate structure or sale of substantially all of OpenSecure’s assets. OpenSecure may also disclose information to third parties as OpenSecure, in its sole discretion, believes necessary or appropriate in connection with the merger or consolidation with, or sale of assets to, such third party, provided that such third party agrees to comply with OpenSecure’s Privacy Policy.

 

Use of System

 

You represent and warrant that any data you provide to OpenSecure is submitted in connection with transactions conducted for business purposes only. Access to and use of the websites and services are subject to this Privacy Policy and to the applicable Agreement(s) between your company and OpenSecure.

 

Data Retention

 

OpenSecure will retain your information for as long as your account is active or as needed to provide you with services, comply with our info obligations, resolve disputes and enforce our Agreements.

 

International Data Transfers

 

You consent to OpenSecure, its affiliates, third-party service providers and partners transferring your personal data to OpenSecure, its affiliates and the recipients referred to in this Privacy Policy in countries outside the European Economic Area (the “EEA”), (including the United States of America), which do not provide a similar or adequate level of protection to that provided by countries in the EEA from which you may have submitted your personal data, if applicable. We will utilize appropriate safeguards governing the transfer and usage of your personal information.

 

Privacy Shield

 

OpenSecure understands that Privacy Shield is no longer an acceptable mechanism for data transfers and now relies on the standard contractual clauses. OpenSecure continues to maintain its Privacy Shield certification in hope that regulators will create a successor program where the transition will be easier for those who participated in Privacy Shield.

 

OpenSecure commits to resolve complaints about the collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding OpenSecure’s use of personal data in accordance with the Privacy Shield Framework should first contact OpenSecure at info@opensecure.co.

 

If you have an unresolved privacy or data use concern that We have not addressed satisfactorily, you may contact our U.S.-based third-party dispute resolution provider at https://feedback-form.truste.co/watchdog/request free of charge.

 

Under certain conditions that are more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

 

OpenSecure is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). In certain situations, OpenSecure may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

OpenSecure complies with the Privacy Shield’s Principle regarding accountability for onward transfers. OpenSecure remains liable under the Principles if its onward transfer recipients process personal information in a manner inconsistent with the Principles unless OpenSecure proves that it was not responsible for the event giving rise to the damage.

 

OpenSecure commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities regarding human resources data transferred from the EU and Switzerland in the context of the employment relationship.

 

Contact Us

 

If you have any questions, please use the appropriate contact below:

 

Accessing and correcting User Information: info@opensecure.co

 

Questions about marketing communications: info@opensecure.co

 

Questions about this Privacy Policy or about OpenSecure’s handling of your information: info@opensecure.co

 

OpenSecure, LLC