EDRANS - PRIVACY NOTICE AND POLICY

This Privacy Notice and Policy is effective as of May 17, 2022 and is regularly updated, with an updated effective date, to reflect any changes in applicable laws or any changes in the way we handle personal information.  

Your privacy is important to us. Edrans, a subsidiary of Netrix, LLC, is a leading provider of public Cloud solutions, DevOps-as-a-Service, and other IT services. This Privacy Notice and Policy ("Policy") applies to you only if are located in the United Kingdom (“UK”), a member state of the European Union (“EU”) or the European Economic Area (“EEA”).  If you are a resident of the United States of America or located elsewhere, please see the Netrix Privacy Notice and Policy.

This Policy explains how Edrans (“Edrans,” “we” and “our”) manages the personal information we obtain:  

·        from our clients, vendors and business partners;

·        from or about individuals in the course of providing services to our clients or operating our business generally; and

·        from operating our websites, collaboration sites, blogs, and other digital media.

The Policy also explains the rights and choices you have in relation to our management of your personal information.  As used in this Privacy Notice, “personal information” refers to any information relating to you as a person.  This includes data that can identify you by itself, such as your name, or it may be information that identifies you only when combined with other available information, such as your social media username when combined with your email address.  

For purposes of this Policy, Edrans includes Edrans Iberia, S.L. (Spain), Edrans UY S.A. (Uruguay), Edrans S.A. (Argentina), and Edrans MX S.A. de C.V. (Mexico).

A.    Information Collected

As a business-to-business provider of Cloud and IT services, we may collect information about employees of our current and potential business customers and use that information to provide and market our products and services, enter into contracts for services, install, support and bill for services, and otherwise carryout our commercial relationship with such customers.  Such information may include all types of identifiers and contact details (such as email, phone numbers, job title, and physical address) and commercial information (such as history and records of products and services you have obtained from Edrans). 

For employment and recruitment purposes, Edrans may also collect and process additional personal information consistent with applicable law that may include national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, calendar availability and scheduling information for meeting and communication purpose, and education background and employment history.  Edrans may also collect health/medical information to accommodate a disability or illness (subject to applicable legal requirements and limitations), financial information for payroll/benefits purposes, performance feedback and development reviews, and information associated with background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies.

We may also collect information directly from you which you provide on Edrans websites, collaboration sites, partner and client portals, blogs and other digital media (collectively “Sites”), over the phone, pursuant to our customer, vendor and channel partner intake processes, or in any other way.  For example, we may collect your name, work title, email address, postal address, phone number, demographics, payment information, user ID, password, and other information you may provide on our Sites, such as when you complete a transaction, register for an account, log in to our Sites, subscribe to or request our services, participate in an event, contest or survey, or contact our customer service representatives.  We may also obtain information about you indirectly from other sources and combine that with information we collect directly from you.  

In addition, when you visit our Sites, some information about your visit is automatically collected, such as your device's operating system, application software, Internet Protocol (IP) address, access times, browser type and language, peripherals, user log data, Active Directory information, and the Sites you visited before and after our website. We also collect (directly or via third parties) information about your usage and activity on our websites, including information about your orders, purchases, and cart activity through essential and non-essential cookies, Web beacons, and similar tracking technologies.

B.    Sensitive Personal Data and Biometric Information

Edrans does not generally collect sensitive data (also known as special categories) through our Sites or otherwise.  The term "sensitive data" (also known as special categories in the EEA) refers to certain categories of personal information identified by data privacy laws as requiring special treatment, and include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, and sexual life or orientation. Edrans may also collect biometric information for specific purposes such as fingerprint authentication.  In the limited instances when such sensitive data or biometric information may be collected, it is done in accordance with data privacy law requirements and/or with your consent.

C.    Cookies and Similar Technologies

We also use cookies and similar technologies on our Sites.  Cookies are small text files placed on your computer hard drive.  Cookies may include information such as the number of times you access the Sites or view a particular page or other item on a Site.  This allows us to analyze traffic to our Sites and thereby improve our Sites and your experience by seeing which areas and features are popular and understand usage and to measure the efficacy of our marketing and awareness campaigns.

By continuing to use our Sites, you consent, where such consent is necessary and valid under applicable law, to our use of cookies and the placement of these cookies on your device for the purposes described.

Many internet browsers are set to accept Cookies by default, and only you have the ability to manage your browser settings.  The “help” section of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies, and how to disable or delete cookies altogether.  

D.   Security and Protection of Your Information

Edrans protects your personal information in accordance with our data privacy policies and applicable laws.  This includes maintaining appropriate technical, physical and organizational measures to protect your personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access.  Our policies and practices include protocols, controls, procedures and guidance to maintain these measures which take into account the risks associated with the categories of personal information and the processing we undertake.  These industry-standard measures are designed and implemented to ensure a level of security appropriate to the risks represented by the processing and the nature of the personal information. We take reasonable technical, physical, and administrative steps to help protect the personal data we collect, transmit, process and store.  

Edrans may store and process your information in the United States and other countries that may not have the same level of protection as your jurisdiction, including allowing access by our staff.  We will take all steps legally required and otherwise reasonably necessary to ensure that your information is treated securely and in accordance with this Policy and applicable law, including with respect to transfers from the EU/EEA.  As permitted by applicable law, you may request details about the suitable safeguards we have in place by contacting us as detailed below.

E.    Purpose of Information We Collect and Legal Basis

We may use information collected for the purposes described in this Policy or as otherwise disclosed to you on our Sites or in connection with our services. Examples of the purposes for our collection and use of such information include: 

• Providing and delivering products and services requested by our customers; 
• Administering the accounts of our customers, partners and vendors; 
• Sending transaction information, including confirmations, invoices, technical notices, product and services information, updates, security alerts, and support and administrative messages;
• Responding to comments and questions about our services and providing customer service;
• Monitoring, operating and improving our Sites, systems, and services;
• Complying with legal and contractual obligations;
• Carrying out business intake procedures; 
• Marketing our products and services;
• Servicing our employees and recruiting new employees; and
• Establishing, exercising or defending legal claims; and
• Social listening to understand the online conversation about our products, services, clients and partners. 

Our legal bases for the foregoing purposes include (a) the performance of a contract or compliance with other legally-imposed obligations, (b) our legitimate interests for ensuring we recruit the appropriate employees, (c) our legitimate interests for ensuring proper communications with our employees, clients and business partners, (d) our legitimate interests for ensuring the proper functioning of our business operations, (e) our legitimate interests for successfully and properly conducting our business, (f) our legitimate interests in protecting our brand and assets on social media, and (g) our legitimate interests in securing our networks and providing customers with a great user experience. 

Legitimate interest means that we have reasonable grounds to process your personal information.  We will decline to use your personal information for the foregoing purposes if your interests and fundamental rights outweigh our legitimate business interests.  You have the right to ask us not to process your personal information for marketing purposes.  If you refuse to provide information to us or if you request that we stop processing information about you, we may not be able to provide the same level of service to you.  

F.     Retention of Your Information

Subject to Section I below, we will retain your personal information only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal information are deleted after a reasonable time according to the following retention criteria:

We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).
We will only keep the data while your account is active or for as long as needed to provide services to you.
We retain your data for as long as needed in order to comply with our global legal and contractual obligations.

G.   Transferring Your Information

As Edrans continues to develop its business, it might sell or buy other companies or assets or be acquired or have substantially all of its assets acquired by a third party. In such transactions, customer information generally is one of the transferred business assets.  You hereby consent to the transfer of your information as one of the transferred assets and to be used for any purpose allowed under this Policy.  As a global organization, personal information we collect may be transferred or be accessible internationally throughout Edran’s global business and between its entities and affiliates.  Any such transfers take place in accordance with the applicable data privacy laws.

Unless you are otherwise notified, any transfers of your personal information located within the EEA to third parties outside the EEA are based on an adequacy decision or are governed by the standard contractual clauses.  Any other non-EEA related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.

H.   Sharing Your Information

Ways we may share your information with third parties, consistent with this Policy and applicable law, are as follows:

·        Third Party Vendors/Service Providers.  We may rely on third-party vendors, consultants and other service providers to perform functions on our behalf and under our instructions in order to make our Sites available to you.  For example, we may engage vendors/service providers for auditing, compliance, and corporate governance functions

·        Edrans Suppliers and Distributors.  We may share your information with suppliers and distributors to Edrans for their internal purposes including administrative purposes, as well as to improve performance, products and services; and for purposes relating to proposed or completed transactions facilitated by Edrans;

·        Business Partners. We may share your information with third parties with whom we do business, including to facilitate your purchase of a product manufactured by an Edrans partner, or for their own marketing purposes in compliance with applicable laws and subject to their separate privacy policies;

·        Legal Obligations and Rights.  In connection with: (i) the establishment, exercise, or defense of legal claims; (ii) to comply with laws or to respond to lawful requests and legal process; (iii) to protect the rights and property of Edrans, our agents, customers, and others, including to enforce our agreements, policies, and terms of use; (iv) to detect, suppress, or prevent fraud; (v) to reduce credit risk and collect debts owed to Edrans; (vi) an emergency to protect the personal safety of Edrans, its customers, or any person; or (vii) as otherwise permitted by applicable law.

·        Business Reorganization. In connection with or during negotiation of any substantial corporate transaction, such as a merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

·        Consent.  We may share your information for any other purposes with your explicit consent.

We may also share aggregated or anonymized information in a form that does not identify you. 

I.      Your Rights and Choices

Email and Marketing Choices.  You may ask us not to process your personal information for marketing purposes. In some jurisdictions, you also have the right to opt-out of the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. You can exercise your right to prevent such processing by: (i) following the opt-out instructions in promotional emails; (ii) checking certain boxes on the forms we use to collect personal information; or (iii) contacting us directly at privacy@edrans.com. You may also make requests about your contact preferences and changes to your information by using the foregoing email or by contacting your account manager. If you opt-out of promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.  In addition, if explicit consent is the basis for processing your personal information, such consent may be withdrawn at any time by providing notice to privacy@edrans.com.  

Pursuant to the General Data Protection Regulation (GDPR), data subjects in the European Union (EU) and the European Economic Area (EEA), to include the UK may exercise certain rights to access their personal information, subject to certain limitations as set forth in this Policy.  Specifically, this Policy applies to visitors from the EU or EEA, including the UK, who access our Sites and when we process personal information of or for business customers within the scope of Article 3 of GDPR and we are acting as a Data Controller when processing that personal information.

EU and EEA data subjects have the right to exercise certain choices regarding the use of their personal information for marketing purposes, as detailed above and in our Cookie Policy. These rights include the right to rectification and erasure, restriction of data processing, and the right to data portability.  If an EU or EEA data subject considers that the processing of personal information relating to him or her infringes the GDPR, such data subjects may also (a), invoke binding arbitration when other dispute resolution procedures have been exhausted and (b) without prejudice to any other administrative or judicial remedy, lodge a complaint with a supervisory authority in the Member State of the data subject’s habitual residence, place of work or place of the alleged infringement. 

Any transfers of personal information of EU/EEA data subjects to third parties located outside the EU/EEA will be based on an adequacy decision of the European Commission or are governed by the standard contractual clauses unless we provide notification to the contrary.  Any other non-EU related transfers of your personal information will take place in accordance with the appropriate international data transfer mechanisms and standards.  Edrans may be required to disclose personal information of EU/EEA data subjects in response to lawful requests by public authorities, including in order to satisfy national security or law enforcement requirements.

J.      Third-Party Websites

Except for Edran’s own online activities on third-party websites and online services where we post our Policy, this Policy does not apply to, and Edrans is not responsible for, any other data practices of third-party websites and online services or the practices of other third parties. To learn about third-party data practices, please review their respective privacy policies.

K.    Inquiries

Please contact us at privacy@edrans.com if:

·        you wish to request information regarding our use or disclosure of your information;
·        you have any questions about this Policy, 
·        you wish to exercise your rights in relation to your personal information rights;
·        you wish to make a complaint about our use of your personal information.

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