S44 Holdings, Inc. Privacy Notice
Last updated: 10/01/2020
S44 Holdings, Inc. (referred to as“our”, “us” and “we” in this notice) is a software development consultancy. Wehelp our clients to provide cutting edge digital experiences to theircustomers. We believe that the responsible use of data supports business growthand builds strong relationships between brand and consumer. As a business, weare committed to respecting and protecting the privacy of all individuals withwhom we interact. We are committed to being always transparent in our handlingand processing of personal data in accordance with applicable privacy and dataprotection laws.
This Privacy Notice explains indetail the types of personal data we may collect about you when you interact withus on any website where this Privacy Notice appears. S44 Holdings, Inc. is thedata controller of any personal data you provide to us, including in relationto this website.
The California Consumer PrivacyAct of 2018 (“CCPA”) provides California residents with additional rights withrespect to their personal information. Those rights are explained below inSection 7 (Your California Rights). This Privacy Notice includes certaindisclosures required under CCPA.
This Privacy Notice explains thefollowing:
In the Supplementary Information section of this Privacy Notice, we explainwhat is meant by “personal data”, “personal information” and other terms usedin this notice.
1. INFORMATION WE MAY COLLECT
The type of information we collect will depend on the circumstances and theservice you are using. We will collect information relating to you and/or youruse of our services in the following ways:
Information relating to your useof the website
We and our third-party service providers automatically collect informationabout the device(s) you use to access our website. This includes collectinginformation about the type of device you are using, as well as unique mobiledevice ID or the internet protocol (IP) address online identifiers, which arenumbers that can uniquely identify a specific computer or other network deviceon the internet. This information is linked to a cookie ID, which we receiveand process. You may find more information on the cookies we use and thepurposes for which we use them on our Cookie Notice below. We also collectinformation about your internet service provider and domain name and the typeof browser and operating system you are using.
We collect contact details directly from you when you sign-up to receive emailalerts, attend one of our events, download our content, subscribe to ournewsletters or where you ask us to respond to a query you have. The personaldata we collect may include your name, email address, employer and job title,and location.
Marketing and communicationspreferences
We collect information about your preferences in receiving marketinginformation from us and your communication preferences.
2. HOW WE USE THIS INFORMATION
• to deliver the specific information or services you have requested;
• to enable the download of our content;
• to send you newsletters and advertising messages (these may containinformation relating to our brands and services);
• respond to your requests and feedback;
• to analyze and/or improve our websites and services; and
• to protect S44 Holdings, Inc., our websites, customers, employees, andbusiness partners from fraud or other malicious activity.
In the table below we set outfurther information about the purposes for which we use your personal data andthe legal basis we rely on for its use. Note that we may process your personaldata for more than one lawful basis depending on the specific purpose for whichwe are using your data. In the second column, we also specify how such personaldata is categorized under CCPA. For more information about the categories ofpersonal information under CCPA, see Your California Rights.
Purpose/Activity Types of personaldata that may be processed (and CCPA categories of personal information) Typesof personal data that may be processed (and CCPA categories of personal information)*
To send you information about our services:
• To send you information whichyou have requested e.g., newsletters or publications in accordance with yourspecified preferences
(b) Email address
(d) General location
(Identifiers: personalinformation; professional or employment related information) Where you haverequested information from us, such as newsletters, publications or eventinvitations, we send such communications based on your consent. You can ask usto stop such communications at any time by clicking on the unsubscribe link atthe bottom of the message.
To improve and develop our website:
• We conduct statistical analysison your usage of the website e.g. to enable us to improve our website, offernew features and material etc.
(Identifiers: internet or othersimilar network activity) Necessary for our legitimate interest (to definetypes of clients for our services, to keep our website updated and relevant, todevelop our business and to inform our marketing strategy).
To deliver relevant content to you, and measure or understand the effectivenessof the content we serve to you.
(b) Email address
(d) General location
(f) Marketing and communications
(Identifiers; personalinformation; professional or employment related information; internet or othersimilar network activity) Necessary for our legitimate interests (to study howclients use our service and engage with our content. To develop our service, togrow our business and to inform our marketing strategy).
• To respond to any enquiries or feedback that you send us
• To update you with any changes to our terms and conditions/other policies
(b) Email address
(d) General location
(Identifiers; personalinformation; professional or employment related information) It is in ourlegitimate interest to respond to communications that you send to us, informyou of relevant information in relation to the services that we provide andutilize your information to improve our business.
To send you information on our products and services relevant to your needs
(b) Email address
(c) General Location
(Identifiers; personalinformation; internet or other similar network activity)
It is our legitimate interests to work out which of our products or servicesmay interest you and tell you about them.
To protect this website, our company, our employees, and our users frommalicious attacks, hacking, fraud, or other illegal or unauthorized activity
(b) Email address
(c) General Location
(Identifiers; personalinformation; geolocation data; internet or other similar network activity) Itis our legitimate interests to investigate and take steps to prevent potentialfraud or other wrongdoing.
To share information with our service providers.
(b) Email address
(d) Marketing and communications
(Identifiers; personal information;internet or other similar network activity)
It is our legitimate business interest to share your data with trusted thirdparties who provide us with services relevant to the provision of our website.
To share information with otherthird parties, such as regulator and law enforcement agencies
(b) Email address
(Identifiers; personalinformation; internet or other similar network activity; geolocation data) Weshare your data as necessary for compliance with any legal obligation to whichwe are subject or in order to satisfy our legitimate business interests.
5. YOUR CHOICES
You have certain choices about how we use your information.
You can control cookies and tracking tools. To learn more about your choicesrelated to cookies and our Do-Not-Track Policy, please see our Cookie Notice.
You may choose not to receivemarketing communications from us. You can ask us to stop such messages at anytime by clicking on the “unsubscribe” link at the bottom of the message. Pleasenote that even if you choose not to receive marketing communications from us,you still may receive non-marketing communications, such as responses to yourinquiries or notices regarding your account or our relationship with you.
6. YOUR EU/EEA RIGHTS
Under EU data protection law we are required to advise you on the legal basisfor processing your personal data. For the most part, the processing of yourpersonal information is based either on a) our legitimate interests related tous providing you services you have requested or otherwise your customerrelationship with us, or b) your consent, where requested.
Where provided under applicablelaw, you may have the following rights:
• Object to our processing of yourpersonal data where we are relying on legitimate interest (or those of athird-party), and you want to object to processing on this ground, as you feelit impacts on your fundamental rights and freedoms. You also have a right toobject where we are processing your personal data for the purposes of directmarketing or profiling. You can object at any time and we shall stop processingthe information you have objected to, unless we can show compelling legitimategrounds to continue that processing.
• Access your personal data. If you make this kind of request and we holdpersonal data about you. We are required to provide you with information on it,including a description and copy of the personal data and why we are processingit. We will require you to prove your identity before granting access to yourpersonal data. We will process your request within the timeframe required underthe relevant law.
• Request the transfer of your personal data. We will provide to you or a thirdparty you have chosen, your personal data in a structured, commonly used,machine-readable format. Please note, this right applies to the personal datayou have provided to us; and if we use your personal data on the basis ofconsent or where we used the information to perform a contract with you.
• Request erasure (deletion) of your personal data. You have a right to ask usto delete or remove your data where you have successfully exercised your rightto object (see above), or where we are required to erase your personal data tocomply with local law. Please note, we may be required to retain certaininformation by law and/or for our own legitimate business purpose. But when wedo so, we will inform you
• Request correction or updating of your personal data. This enables you tohave any incomplete or inaccurate data we hold about you corrected.
• Request the restriction of our processing of your personal data in somesituations. If you request this, we can continue to store your personal databut are restricted from processing it while the restriction is in place.
• Withdraw your consent. Where you have provided your consent to our processingof your personal data you can withdraw your consent at any time. If you dowithdraw consent, that will not affect the lawfulness of what we have done withyour personal data before you withdrew consent.
• Make a Complaint. We will do our best to resolve any complaint. However, ifyou feel we have not resolved your complaint, you have a right to make acomplaint to your local data protection authority.
• If you exercise the rights above and there is any question about who you are,we may require you to provide information from which we can satisfy ourselvesas to your identity.
7. YOUR CALIFORNIA RIGHTS
This section describes the rights that residents of California have and inother jurisdiction as provided by local law, and how to exercise such rights.
1. Right to Know about PersonalInformation Collected, Disclosed or Sold
You have the right to request that we disclose certain information to you aboutour collection, use, disclosure or sale of your personal information over thepast 12 months. Once we receive and confirm your verifiable consumer request(see Exercising Access and Deletion Rights), and subject to certain limitationsthat we describe below, we will disclose such information. You have the rightto request any or all of the following:
• The categories of personalinformation we collected about you.
• The categories of sources from which the personal information is collected.
• Our business or commercial purpose for collecting or selling that personalinformation.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (alsocalled a data portability request).
2. Right to Request Deletion
You have the right to request that we delete any of your personal informationthat we collected from you and retained, subject to certain exceptions. Once wereceive and confirm your verifiable consumer request (see Exercising Access andDeletion Rights), we will delete (and direct our service providers to delete)your personal information from our records. However, we may retain personalinformation that has been de-identified or aggregated. Furthermore, we may denyyour deletion request if retaining the information is necessary for us or ourservice provider(s) in order to perform certain actions, set forth under CCPA,such as detecting security incidents and protecting against fraudulent orillegal activity.
3. Exercising Access and Deletion Rights
Please submit a request to us by emailing us at firstname.lastname@example.org
Only you, or a person or businessentity registered with the California Secretary of State that you authorize toact on your behalf (an “authorized agent”), may make the requests set forthabove. You may also make a request on behalf of your minor child.
The request should include yourcontact information and describe your request with sufficient detail thatallows us to properly understand, evaluate, and respond to it. In addition, youshould provide sufficient information (including information that reasonablyenables us verify the identifying information we currently maintain about you)that allows us to reasonably verify that you are the person about whom wecollected the personal information or an authorized representative.
We will respond to consumerrequests in a reasonably timely manner. If we require extra time to respond, wewill inform you of the reason and extension period in writing. In order to protectthe security of your personal information, we will not honor a request if wecannot verify your identity or authority to make the request and confirm thepersonal information relates to you. The method used to verify your identitywill depend on the type, sensitivity and value of the information, includingthe risk of harm to you posed by any authorized access or deletion. Generallyspeaking, verification will be performed by matching the identifyinginformation provided by you to the personal information that we already have.
Any disclosures we provide willonly cover the 12-month period preceding our receipt of your request (and willnot be made more than twice in a 12-month period). If we cannot comply with arequest, or cannot fully comply with a request, the response we provide willalso explain the reasons we cannot comply.
We will not discriminate against you for exercising any of your CCPA rights,including, but not limited to, by:
• Denying you goods or services.
• Charging you different prices or rates for goods or services, includingthrough granting discounts or other benefits, or imposing penalties.
• Providing you a different level or quality of goods or services.
• Suggesting that you may receive a different price or rate for goods orservices or a different level or quality of goods or services.
8. OUR RESPONSIBILITY FOR WEBSITELINKS
This Privacy Notice is limited to the personal data collected by S44 Holdings,Inc.. We do provide links within this site to other websites, including socialmedia sites such as Facebook, Twitter and LinkedIn. If you follow these links,your use of these sites will be governed by their applicable user and privacynotices since their data practices fall outside the scope of this PrivacyNotice. Further, we can have no responsibility for or control over theinformation collected by any third-party website and we cannot be responsiblefor the protection and privacy of any information which you may provide on suchwebsites.
This Privacy Notice may be updated from time to time to reflect changes in law,best practice or a change in our practices regarding the treatment of personaldata. The date of the most recent revision will appear at the top of this page.If you do not agree to the changes, please do not continue to use our servicesand please refrain from sharing your personal data with us. You should checkthis notice frequently for updates.
This website is not intended for children aged 16 or under. We do not activelyseek to collect personal data about children aged 16 or under. If you have anyconcerns about your child’s privacy in relation to our services, or if youbelieve that your child under the age of 16 may have entered personal data ontoour website, please contact us at email@example.com. We will delete suchpersonal data from our records or seek verifiable parental or legal guardianconsent to retain such information within a
11. CONTACT US
If you have any questions about this Privacy Notice, our approach to privacy oryou would like to exercise any of the rights mentioned in this Privacy Noticeyou can contact our Data Protection Officer in any of the following ways:
S44 Holdings, Inc.
135 Chestnut Ridge Road, Suite 1100
Montvale, NJ 07645
Toll Free Phone: US (201) 391-5675
In this Supplementary Information section, we explain some of terminology usedin this Privacy Notice.
“data controller” – the person orcompany that controls the purposes and means of processing personal data.
“personal data” – any information that relates to you (or from which you can beidentified).
“personal information” – information that identifies, relates to, describes,references, or is reasonably capable of being associated with, or couldreasonably be linked, directly or indirectly, with a particular consumer orhousehold. “Personal information” excludes information that is lawfully madeavailable from federal, state or local government records as well as de-identifiedor aggregated information.
“processing” – means doing anything with data. For example, it includescollecting it, holding it, disclosing it and deleting it.
“profiling” – using automated means to process personal data in order to workout certain things about people, like analyzing or predicting their performanceat work, reliability, economic situation, personal preferences, interests,behavior, location or movements.
“transfer” – sending personal information outside the European Economic Area (e.g.by storing it on equipment located outside the European Economic Area), orallowing someone from outside the European Economic Area to access the personalinformation.
Please read below for more information on the cookies we use, the purposes forwhich we use them, and how to reject cookies.
How to reject cookies
Our Do-Not-Track Policy: If you don’t want to receive cookies, you can alteryour browser settings. The procedure for doing so varies from one browserapplication to another. If you wish to reject cookies from our site, but wishto accept those from other sites, you may choose the option in your browsersettings to receive a notice before a cookie is stored on your device. If youblock or reject cookies, not all of the tracking described below will stop.Please consult the “Help” section of your browser for more information.
To find out more or to opt out ofhaving your online behavior collected for advertising purposes, please consultthe following: http://www.allaboutcookies.org/manage-cookiesand www.youronlinechoices.com (for EU users) or http://optout.aboutads.info/?c=2&lang=EN(for U.S. users). Choices you make are device-specific and browser-specific. Bydisabling cookies, you may be prevented from accessing some features of oursite or certain content or functionality may not be available.
How we deploy “cookies”
Cookies are small packets of information stored by your web browser when youvisit certain websites, including our website. Cookies are generally used bywebsites to improve your user experience by enabling that website to ‘remember’you, either strictly for the duration of your visit (using a “Session” cookiewhich is erased when you close your browser) or for repeat visits (using a“Permanent” cookie).