- Transparency/Notice–What Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third Party-sources) and our privacy practices depend on the nature of the relationship you have with Amberdata and the requirements of applicable law. We endeavor to collect information only relevant for the purposes of Processing. Below are the legal bases and some of the ways we collect information and how we use it.
- Information Amberdata Collects
The data we collect from or about current, prospective and former clients, Employees, customers, visitors and guests (collectively “Individuals”) includes information that may be deemed Personal Information, such as title, name, email address, phone number, user name, photo or image, Internet Protocol address, and credit card and other financial information related to payments for services or goods. We may also collect other information that is not Personal Information, such as demographic information you choose to provide (e.g., your business or company information, professional experiences, educational background, gender, interests, preferences and favorites) and answers to security questions and passwords.
- How Amberdata Collects Personal Information
Some of the ways that Amberdata may collect your Personal Information include:
Amberdata may collect Personal Information from you through various channels, including the Websites, in surveys, during business or marketing events, and when providing the Services to you.
If you create an Account, we’ll collect Personal Information and other information that is not Personal Information in connection with you registration. If you create an Account using your login credentials from one of your TNS Accounts, we’ll be able to access and collect your name and email address and other Personal Information that your privacy settings on the TNS Account permit us to access.
When you use the Websites, Amberdata may provide you with opportunities to sign up to receive specific information or services and may ask for your contact information (e.g. name, home address, home phone number or personal email address), so that we can send you specific information about our products and services, with your consent.
Amberdata may also collect Personal Information from your use of the Services to analyze use of the Services and learn about the interests of our Users in the aggregate and also on a personal level.
As you navigate the Websites, certain passive information may also be collected, including Internet Protocol addresses, cookies, navigational data, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, the date and time you access our Websites, and the Internet address of the website from which you linked directly to our Websites. This type of information is used for the purposes of gathering data to provide improved administration of our Websites, and to improve the quality of your experience when interacting with our Websites.
- Information from Third-Party Sources
Amberdata may collect information about you from Third-Party sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided to Amberdata and to enhance our ability to provide you with information about our business, products and services. Amberdata’s agreements with these Third Party-sources typically limit how the Company may use this supplemental information.
- How Amberdata Uses Your Personal Information
Depending on how you interact with Amberdata, we and our Third Party-service providers may also use Personal Information in a variety of ways, including:
Providing Information and Services You Requested. Amberdata may use your Personal Information to provide the Services to you. Such use may include: (a) generally managing your information and Account; (b) responding to questions, comments and requests; and (c) providing access to certain areas and features of the Services. Amberdata may also use the Personal Information about you to provide you information that you may request, e.g. information about a products or services we are offering.
Administrative Purposes. Amberdata may use the Personal Information about you for its administrative purposes, including, without limitation, to: (a) measure interest in Amberdata’s Services; (b) perform internal quality control; (c) verify identity; (d) send communications regarding the Amberdata Services, your Account, or any changes to any Amberdata policy or terms of service; (e) process payments; (f) prevent potentially prohibited or illegal activities; and (g) enforce our Terms of Service.
Marketing Products and Services. Amberdata may use the Personal Information about you to provide you with materials about offers, products and services that may be of interest to you, including new content or features available through the Services. Amberdata may provide you with these materials by phone, postal mail, facsimile or email, as permitted by applicable law. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.
Research and Development. Amberdata may use your Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our products and services or develop new products, processes and services.
Sharing Content. The Services may offer various tools and functionality for sharing Content. For example, Amberdata may provide functionality on the Services that will allow you to forward or share certain content with other Users or with Third-Party Services.
Feedback, Comments and Other Communications You agree that Amberdata is free to use the content of any communications or other information submitted by you via the Services, including any narratives, images, ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or services.
Other Uses. Amberdata may use your Personal Information for other purposes disclosed to you at the time you provide such Personal Information or with your consent.
- Social Media
Generally, online social media resources are interactive tools that enable Data Subjects to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague.
Amberdata may collect Personal Information to enable you to use online social media resources offered either by Amberdata or in connection with your TNS Accounts. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.
- Direct Mail, Email and Outbound Telemarketing
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 Amberdata or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions in Section 3 below.
- Cookies, Pixel Tags/Web Beacons, and Analytics Information
Like many other Services, Amberdata or its business partners may employ a cookie, or small piece of computer code that enables Web servers to “identify” visitors, each time an Individual initiates a session on the Company’s Websites. A cookie is set in order to identify Data Subjects; tailor our Websites to you; measure and research the effectiveness of our Websites’ features, offerings and advertisements; and authenticate users for registered services. Cookies can only access Personal Information that you have provided on our Websites and cannot be accessed by other sites.
- Pixel Tags/Web Beacons
Amberdata may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Services. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the browser type and language; the device type; geographic location; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we or our Third Party-service providers may use “format sensing” technology, which allows pixel tags to let us know whether you received and opened our email.
- Analytics Information
Google. We use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Websites, 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.
We use a service provided by Mixpanel, Inc. (“Mixpanel”) to provide us with analytics data regarding users’ interactions with our Site and Services. You may opt-out of Mixpanel’s automatic retention of data that is collected while using the Services by visiting https://mixplanel.com/optout/. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Mixpanel opt-out cookie.
- Mobile Devices
Amberdata may provide websites and online resources that are specifically designed to be compatible and used on mobile devices. Amberdata will collect certain information that your mobile device sends when you use such websites or online resources, like a device identifier, user settings and the operating system of your device.
- Location Information
When you use our Services, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
- Anonymous and Aggregated Information
Amberdata may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Services or other online services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Amberdata may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within Amberdata and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
- Interest-Based Advertising
Through our Websites, Amberdata may in the future allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect anonymous, non-Personal Information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information 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-Amberdata related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”
- Choice/Modalities to Opt Out
Where you have consented to Amberdata’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this Section 3. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.
Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject, Amberdata will endeavor to obtain each Data Subject’s explicit consent (opt-in). Where consent of the Data Subject for the Processing of Personal Information is otherwise required by law or contract, Amberdata will comply with the law or contract.
- Email and Telephone Communications
- “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. Amberdata does not recognize or respond to browser-initiated DNT signals. For information about “do-not-track”, visit http://www.allaboutdnt.org.
- Advertising Choices
You can opt out of the collection and use of your information for interest-based advertising by going to http://optout.aboutads.info or http://www.youronlinechoices.eu/ to limit collection through the Website or by configuring the settings on your mobile device to limit ad tracking through the mobile applications.
Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Websites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
- Onward Transfer
- Information We Share
- Service Providers
Amberdata may share Personal Information with our service providers that we have retained to perform services on our behalf including (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.
Amberdata has executed appropriate contracts with the service providers that prohibit them from using or sharing your personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Business Partners
Amberdata may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Amberdata 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 for any purpose other than the purpose for which it was provided.
- Information Disclosed for Our Protection and the Protection of Others
We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce Amberdata policies or contracts; (v) to collect amounts owed to Amberdata; (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.
- Information Disclosed in Connection with Business Transactions
- Data Transfers
All Personal Information sent or collected via or by Amberdata may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Amberdata, you consent to the storage of your Personal Information in these locations.
- Rights of Access, Rectification, Erasure and Restriction
The security of all Personal Information provided to Amberdata is important to us, and Amberdata takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Amberdata strives to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to Amberdata, and you do so at your own risk. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify Company at firstname.lastname@example.org.
- Redress/Compliance and Accountability
email@example.com. Amberdata will address your concerns and attempt to resolve any privacy issues in a timely manner.
- Other Rights and Important Information
- Information Regarding Children Due to the nature of Amberdata’s business, services and benefits are not marketed to minors. Amberdata does not knowingly solicit or collect Personal Information from children under the age of 13 (and in certain jurisdictions under the age of 16). If we learn that we have collected Personal Information from a child under the age of 13 (and in certain jurisdictions under the age of 16), we will promptly delete that information.
- California Privacy Rights California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Amberdata does not share Personal Information with third parties for their own marketing purposes.
“Data Subject” is an identified or identifiable natural person. A Data Subject may be an Employee, an Individual or any other natural person.
“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker or retiree of Amberdata or its subsidiaries worldwide.
“Personal Information” is any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU-residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third Party” is any natural or legal person, public authority, agency or body other than the Data Subject, Amberdata or Amberdata’s agents.