At NetNumber, we recognize the importance of protecting your personal information and are committed to processing it responsibly and in compliance with applicable data protection laws in all countries in which we operate.
In the normal course of its business activities, NetNumber collects, uses, and sometimes shares personal information of various individuals in order to run its day-to-day operations This Privacy Notice describes NetNumber’s general privacy practices that apply to such personal information collection and use.
As part of its core business, NetNumber provides services to customers that may result in NetNumber processing personal information (such as name, telephone number, address, email) on behalf of those customers. In such cases, NetNumber acts as a “data processor” on behalf of the customer (the customer is the “data controller” for the information provided). This Notice does not apply to such processing. The processing of such personal data on behalf of customers will be carried out by NetNumber in accordance with the terms of the relevant contract or contracts between NetNumber and the customer. This Notice applies solely to those instances where NetNumber is the data controller, meaning that NetNumber decides what personal information to collect and how to process it.
This Notice also does not apply to personal information relating to employees, applicants for employment, and temporary contractors providing services to NetNumber, or others in relationships with such persons that are relevant to their relationship with NetNumber (such as for emergency contact and benefits purposes). For information regarding NetNumber’s processing of such data, please refer to NetNumber’s Employee GDPR Policy – EU, which is accessible from NetNumber’s intranet.
WHY WE COLLECT YOUR PERSONAL INFORMATION
NetNumber only collects your personal information when we have a legal basis to do so, such as: (a) on the basis of your contract with us in support of our business operations; (b) when applicable, based upon your consent; or (c) in furtherance of our legitimate business interests, specifically, for advertising and direct marketing purposes; to improve our website(s); to protect and ensure the safety of NetNumber’s website(s), confidential and proprietary information, customers, and employees; and, when applicable, vendor management.
TYPES OF PERSONAL INFORMATION WE COLLECT
NetNumber collects minimal personal information for its marketing and vendor management purposes, such as name, company, email, and other business contact information.
As is true with many websites, we may automatically capture data when you use our website(s), such as the duration of your visit, your browser type and operating system, the pages you visited, and related internet traffic.
HOW WE COLLECT YOUR PERSONAL INFORMATION
NetNumber may collect personal information directly from an individual user or through its customers. While an individual does not have to provide personal information, NetNumber may not be able to respond to requests without such information. Examples of how we collect your personal information directly from you are:
- By filling in forms (for example, a “Contact Us” form) on our website(s) or at a trade show
- By downloading documentation from our website(s)
- By subscribing to newsletters or other NetNumber communications
- By corresponding with NetNumber by phone, e-mail or otherwise using our contact details
When you visit our website(s), we may automatically capture your data through a third-party vendor service, such as Google Analytics.
HOW WE USE YOUR PERSONAL INFORMATION
We only use your data as expressly set forth in this Notice. We use the personal information we collect for marketing and sales purposes. Specifically, we may use your information to:
- Conduct and develop business with the individual and with others
- Process, evaluate and complete certain transactions involving our website(s), products and/or services
- Operate, evaluate, maintain, improve and develop our website(s) (including by monitoring and analyzing trends, access to, and use of the website(s) for advertising and marketing) and/or NetNumber’s products and/or services
- Customize NetNumber’s website(s) to users’ needs
- Engage individuals about events, promotions, and products and services
- Provide individuals with documentation or communications which they have requested
- Correspond with website users to resolve their queries or complaints
- Send marketing communications, where it is lawful to do so
- Protect and ensure the safety of the company’s website(s), confidential and proprietary information, customers, and employees
We utilize the data we automatically capture when you visit our website(s) for sales purposes. If a need arises to use your data for a secondary purpose, we will provide you prior notice of such use.
REASONS WE SHARE YOUR PERSONAL INFORMATION
We do not share your personal information with third parties except as noted herein. We may share your personal information as necessary to maintain business operations, such as with data storage vendors working on our behalf or to conduct further processing, such as website analytics vendors; as required by law or to respond to legal process; to maintain the security of our products and services; to protect NetNumber’s customers, employees, rights, or property; as part of a merger or acquisition; or with your express consent.
WHERE WE STORE AND PROCESS YOUR PERSONAL INFORMATION
Personal data collected by NetNumber may be stored and processed in your region, in the United States, and in any other country where NetNumber and/or its third-party vendors operate and/or have facilities. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this Privacy Notice is processed according to the provisions of this Notice and the requirements of applicable law wherever the data is located. We may transfer personal data from the European Union, European Economic Area, the United Kingdom or Switzerland (collectively, the “EU”) to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data.
HOW WE SECURE YOUR PERSONAL INFORMATION
NetNumber uses a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we have implemented a Corporate Security Program (CSP) that establishes standards and policies to be met by all personnel and contractors and by all equipment owned and/or operated by NetNumber. Among other things, such standards and policies aid in minimizing the potential exposure to NetNumber from the loss or unauthorized use of sensitive or company confidential data, including your personal data. The CSP is made up of many policies that span many content areas, including:
- Information Systems Policy
- Physical and Human Resources Policy
- Emergency Management and Emergency Avoidance Policy
- Vendor and Third-Party Security Policy
Other examples of security measures include the use of encrypted laptops and Secure File Transfer Protocols. Please contact us as indicated below for any questions on our security policies.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We generally retain personal information for as long as we believe is necessary to fulfill the purposes for which it was collected, to respond to complaints, or as otherwise required to meet legal, regulatory, tax, or similar obligations.
HOW TO ACCESS AND CONTROL YOUR PERSONAL INFORMATION
If you want to be removed from our marketing and sales databases or otherwise amend your information, please contact us as indicated below. Where we are processing your information on behalf of a customer, please contact the customer directly for any changes with respect to the collection and processing of your personal information. If you reside within the EU, you may review your options with respect to your personal information here.
NOTICE REGARDING THIRD PARTY PRIVACY PRACTICES & SOCIAL MEDIA
This Privacy Notice applies solely to NetNumber’s website(s). Our site includes links to other, unaffiliated websites. If you access those sites and submit personal information, you are subject to the privacy notices applicable to those sites. We encourage you to carefully read the privacy notice of any website you visit. Please note that we do not share any personal information on social media.
HOW TO CONTACT US
If you have a privacy-related concern, complaint, or question, or need to modify or delete your personal information collected by us, please contact us by email at email@example.com or by post at 650 Suffolk Street, Suite 307, Lowell, MA, 01854, USA.
Art 27, paragraph 1 of the GDPR requires companies that are not established in the EU, but that process the personal data of people within the EU, to appoint an EU-based representative to act as their Europe-facing point of contact for individuals and local data protection authorities.
For Net Number, Inc., not established in the EU, the following legal person becomes the EU-Representative:
K11 Consulting GmbH
Represented by its managing directors: Heike Stoltz Artavia, Dr. Alexander Deicke
Phone: 0049 7141 947532-1
Fax: 0049 7141 947532-6
Register court: District court Stuttgart
The EU Representative is contact point for the responsible supervisory authorities and the data subject with inquiries in connection of ensuring compliance with the General Data Protection Regulation (GDPR/DSGVO).
Further, there is a right to lodge a complaint with data protection supervisory authority (Art. 77 GDPR, in connection with 19 BDSG).
Address of the Country Commissioner for Data Protection and Freedom of Information supervisory authority for Baden-Württemberg is:
CHANGES TO NOTICE
Please note that this Privacy Notice may change from time to time. If there are material changes to this Privacy Notice or in how we use your personal information, we will post a notice on our home page that this Privacy Notice has changed. You are also encouraged to periodically review this Privacy Notice to stay informed on how we are protecting your personal information.
This Privacy Notice is effective as of May 24, 2018.