Engineering Support Services (heretofore called ESS) makes this Policy statement. It covers its entities and branches. The Policy is effective as of December 10, 2020. It applies to all our divisions.
ESS Privacy Commitment
ESS is concerned about your privacy. We ask for only the least amount of information necessary. We gather only what we believe is essential for doing business, or for the specific transaction at hand. We let customers know the information we have on them and allow them to opt out of certain information collection when possible.
The goal of this policy is to make explicit the information we gather on our customers and users, how we will use it, and how we will not. We will try and keep the language as simple and direct as possible.
Part I – Information ESS collects and controls
This part deals with how ESS collects and uses information about website visitors, potential customers, users of ESS’s services and services, and others who contact ESS through forms or email addresses published on or linked to our websites.
Part II – Information that ESS processes on your behalf
This part deals with how ESS handles data that you entrust to ESS when you use our services and services, or when you share any personal or confidential information with us while contacting us.
Part III – General
Part I – Information ESS collects and controls
What information ESS collects
We collect information about you only if we need the information for some legitimate purpose. ESS will have information about you only if (a) you have provided the information yourself, (b) ESS has automatically collected the information, or (c) ESS has obtained the information from a third party. Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.
Information that you provide us
Form submissions: We record information that you submit when you submit a form to request customer support or to contact ESS for any other purpose.
Interactions with ESS: We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.
Information that we collect automatically
Information from browsers, devices and servers: When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol (IP) address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to our websites.
Information that we collect from third parties
Referrals : If someone has referred any of our services or services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may contact us at firstname.lastname@example.org to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.
Information from our service providers: If you register for or attend an event that is ESS sponsors, the event organizer may share your information with us. ESS may also receive information about you from review sites if you comment on any review of our services and services, and from other third-party service providers that we engage for marketing our services and services.
Information from social media sites and other publicly available sources: When you interact or engage with us on social media sites such as Facebook, Twitter, LinkedIn and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our services, or better understand user reactions and issues. Once collected, this information may remain with us even if you delete it from the social media sites. ESS may also add and update information about you from other publicly available sources.
Purposes for using information
In addition to the purposes mentioned above, we may use your information for the following purposes:
- To keep you posted on new services, upcoming events, offers, promotions and other information that we think will be of interest to you;
- To set up and maintain your account, and to do all other things required for providing our services, such as enabling collaboration;
- To understand how customers use our services, to monitor and prevent problems, and to improve our services;
- To provide customer support, and to analyze and improve our interactions with customers;
- To update, expand and analyze our records, identify new customers, and provide services that may be of interest to you;
- To analyze trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;
- To monitor and improve marketing campaigns and make suggestions relevant to the user.
Legal bases for collecting and using information
Legal processing bases applicable to ESS : Our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of ESS or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.
Withdrawal of consent: Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.
Legitimate interests notice: Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.
Your choice in information use
Opt out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive notices and essential transactional emails.
Disable cookies: You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
Optional information: You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.
How we share your information
Third-party service providers: We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organizers, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.
Other cases : Other scenarios in which we may share the same information covered under Parts I and II are described in Part III.
Your rights with respect to information we hold about you
If you are in the European Economic Area (EEA), you have the following rights with respect to information that ESS holds about you. ESS undertakes to provide you the same rights no matter where you choose to live.
Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information’s source, purpose and period of processing, and the persons with whom we share the information.
Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which we originally collected it.
Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
Right to complain: You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.
Retention of information
Part II – Information that ESS processes on your behalf
Information entrusted to ESS and purpose
Information provided in connection with services: You may entrust information that you or your organization (“you”) control, to ESS in connection with use of our services or for requesting support for our services. This includes information regarding your customers and your employees (if you are a controller) or data that you hold and use on behalf of another person for a specific purpose, such as a customer to whom you provide services (if you are a processor). We may store the data on our servers when you use our services or transfer or share it with us as part of a request for support or other services.
Ownership and control of your service data
We recognize that you own your data. We provide you complete control of your data by providing you the ability to (i) access your data, (ii) share your data through supported third-party integrations, and (iii) request export or deletion of your data.
Who we share your data with
Engineering Support Services and third party sub-processors: In order to provide services and support for our services, the contracting entity within Engineering Support Services engages other group entities and third parties.
Employees and independent contractors : We may provide access to your service data to our employees and individuals who are independent contractors of Engineering Support Services entities involved in providing the services (collectively our “employees”) so that they can identify, analyze and resolve errors. We ensure that access by our employees to your service data is restricted to specific individuals and is logged and audited. Our employees will also have access to data that you knowingly share with us for support. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within Engineering Support Services.
Other cases: Other scenarios in which we may share information that are common to information covered under Parts I and II are described in Part III.
Retention of information
We hold the data in your account as long as you choose to use ESS. Once you terminate your ESS account, your data will eventually get deleted from active database during the next clean-up that occurs. The data deleted from active database will be deleted from backups.
Data subject requests
If you believe that we store, use or process your information on behalf of one of our customers, please contact the customer if you would like to access, rectify, erase, restrict or object to processing, or export your personal data. We will extend our support to our customer in responding to your request within a reasonable timeframe.
Part III – General
Children’s personal information
Our services are not directed to individuals under 16. ESS does not knowingly collect personal information from children who are under 16 years of age. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 16 years has provided personal information to us, please write to email@example.com with the details, and we will take the necessary steps to delete the information we hold about that child.
How secure is your information?
At ESS, we take data security very seriously. We have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us. If you have any concerns regarding the security of your data, we encourage you to write to us at firstname.lastname@example.org with any questions.
Locations and international transfers
We share your personal information and service data within Engineering Support Services. By accessing or using our services and services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the United States of America.
Do Not Track (DNT) requests
Some internet browsers have enabled ‘Do Not Track’ (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don’t wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.
External links on our websites
Disclosures in compliance with legal obligations
We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.
Enforcement of our rights
We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.
We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honor our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.
Notification of changes