Last Updated: May 25, 2018
Who we are and how to contact us
Who we are
Our address is: 100 S. Ellsworth Ave, 9th Floor San Mateo, CA 94401, USA.
The Brand Indicators group of companies is made up of different legal entities, including one based in the UK, called Brand Indicators UK Ltd. Brand Indicators UK Ltd’s address is Venture House, 2 Arlington Square, Downshire Way, Bracknell, RG12 1WA.
You can contact us by emailing: email@example.com.
By law you have the right to:
How to exercise your rights
If you want to exercise any of the rights described above, please contact us at: firstname.lastname@example.org..
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at: email@example.com..
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of emails relating to purchases, subscription renewals and customer announcements relating to product/services such as technical notifications, service updates or other administrative communications.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
|Category of Personal Data collected||What this means|
|Identity Data||First name, surname, last name, username or similar identifier and title.|
|Contact Data||Your work address, billing address, email address and telephone numbers.|
|Marketing and Communications Data||Your preferences in receiving marketing from us and our third parties and your communication preferences.|
|Behavioural Data||Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into “segments” (e.g., there may be a segment for Information Security Managers, based in the UK and working in Financial Services).|
|Technical Data||Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.|
No Special Categories of Personal Data
We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
Generally we do not rely on your Consent as a legal basis for using your Personal Data.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
|Fraud Prevention||Identity Data
|To keep our website, our services and associated systems operational and secure.||Legitimate Interests.
We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.
|Troubleshooting||Technical Data||To track issues that might be occurring on our systems.||Legitimate Interests.
It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services.
Marketing and Communications Data
|To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.||Legitimate Interests.
We have a legitimate interest in providing you with updates on our Sites and related offers where you have purchased or shown interest in similar services from us.
Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).
In this case, we may have to stop you using our Site have with us but we will notify you if this is the case at the time.
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
|Third party data source||Publicly available?||Category(ies) or other types of personal data received.|
|Our Affiliates||No||Identity Data
Marketing and Communications Data
|Analytics Providers||No||Behavioural Data
|Lead Generation Service Providers||No||Identity Data
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies:
Cookies we use
Our Site uses the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
|Targeted and advertising cookies||These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.|
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through, or whilst simultaneously logged into, a social networking website such as Facebook. The social network will record that you have done this.|
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com/uk.
In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
The table below describes who we share your Personal Data with, what we share and why we share it.
We share your Personal Data within the members of the Brand Indicators group of companies (i.e. Our Affiliates). We need to send information to members of the Brand Indicators for Message Identification (BIMI) working group moments to support requests to participate in Beta or pilots. This will involve transferring your data outside the European Economic Area (“Europe”).
Many of our external third parties are based outside Europe so their processing of your Personal Data will involve a transfer of data to countries based outside of Europe.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of the Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented
|Recipients||Category(ies) of Personal Data we share.||Why we share it||Location(s)|
|Our Affiliates||Identity Data
Marketing and Communications Data
|Our affiliates help us provide our service and help manage our customer relationships (including providing customer support, customer liaison, sales and marketing etc.).||Within Europe
The United States
|Service Providers||Identity Data
|Our service providers provide us with IT and system administration services.||Within Europe
The United States
|Our Partners||Identity Data
Marketing and Communications Data
|Our Partners help us provide our service and help manage our customer relationships (including providing customer support, sales, customer liaison, sales and marketing etc.).||Within Europe
Australia & New Zealand
Asia Pacific region
|Professional advisers||Identity Data
|Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services.||Within Europe
The United States
|HM Revenue & Customs, regulators and other authorities||Identity Data
|Authorities may require reporting of processing activities in certain circumstances||Within Europe
The United States
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.
As described in the Privacy Shield Principles, Brand Indicators is accountable for Personal Data that it receives and subsequently transfers to third parties. If third parties that process Personal Data on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.
Brand Indicators commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to Personal Data transferred from the EU. Please contact us to be directed to the relevant DPA contacts.
As further explained in the Privacy Shield Principles, binding arbitration before a Privacy Shield Panel will also be made available to you in order to address residual complaints not resolved by any other means. Brand Indicators is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).