Effective date: March 18 2019
Equisolve, Inc. (“Equisolve,” “we,” “us,” or “our”) is committed to protecting the privacy and security of the personal data we process for our clients and that we gather from visitors (“Visitors,” “you,” or “your”) through the public-facing portions of our website, Equisolve.com (our “Site”).
This Privacy Notice (this “Privacy Notice”) applies to the personal data that Equisolve collects and processes in relation to Visitors through this Site, including information that you provide directly or that we otherwise collect from you as described herein. This Privacy Notice also describes your rights related to that personal data.
Equisolve’s core business is designing and developing corporate and investor relations websites for publicly traded companies. For those websites, our clients serve as the data controllers and Equisolve is a data processor acting on their instructions and behalf. Except as described in the Privacy Shield section of this Privacy Notice, or otherwise specified, this Privacy Notice does not apply to Equisolve’s role as a data processor in our core business for clients.
Equisolve’s websites are not intended for use by children and we do not knowingly collect personal data that could identify individual children.
Equisolve only gathers business contact information data through the Site and does not gather any categories of sensitive information, such as data revealing race or ethnicity, political opinions, religion or beliefs, trade union membership, health or sex life, sexual orientation, genetic data, or biometric data.
How We Collect and Use Your Personal Data
It is important that you read this Privacy Notice with special attention given to the specific type of processing activity that is relevant to you and your information, in addition to any other Privacy Notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
Contact Forms & Requests for More Information
When you request for us to contact you, we collect the contact information needed to get in touch with you. This information is added to our CRM system, Infusionsoft, which we use to keep track of our contact with you. If you choose to opt in to email updates about Equisolve, we will send you periodic emails informing you about Equisolve. You may opt out of those emails at any time by clicking the unsubscribe link at the bottom of the email.
When you fill out our employment applications, we collect your contact information and details about your skills and prior employment. This information is used solely for the hiring process and is not shared with any third parties other than those necessary to the hiring process.
Cookies are small packets of data that a website stores on your computer's hard drive so that your computer will "remember" information about your visit. We use a combination of 1st-party and 3rd-party cookies on our Site. First-party cookies are served from the equisolve.com domain and are used as technically necessary to provide the Site and to enable certain features, such as to remember your log-in details. For use of third-party cookies (and related “tracking technologies,” such as pixel tags), please see “Third-Party Tracking Technologies” below.
If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser's documentation for information on how to do this. However, if you decide not to accept cookies from us, the website may not function properly.
Third-Party Tracking Technologies
We use different third-party service providers that utilize tracking technologies, such as cookies and pixel tags. They are as follows:
Google Analytics: General statistics about the usage of equisolve.com. Google Analytics collects your IP address as part of its tracking functionality. This information is reported only in aggregate and your individual IP address is not reported.
Google AdWords: Pixel tags used to track when a Visitor has clicked through to our Site from a keyword search on Google or related AdWords advertisements. This tag assigns a unique ID to the Visitor.
Google Dynamic Remarketing: Pixel tags that allows us to retarget Visitors based on their visit to our Site (i.e., showing ads to our Site to visitors who have already visited the site). This tag assigns a unique ID to the Visitor.
Infusionsoft: Powers our ‘Contact’ page and integrates with Infusionsoft’s backend CRM.
How We Keep Your Personal Data Secure
Equisolve takes the security of all the data we hold very seriously. Preserving the confidentiality, integrity, and availability of the personal data that Equisolve gathers and uses in advertising our web design and development services through this site is essential to Equisolve’s role in serving our business clients.
Security measures that we use include encryption, access controls, audit logs, and operational and technical policies and procedures.
We have policies, procedures, and training in place covering systems and network security maintenance, operations, and monitoring; data classification, confidentiality, security incident response, and others. We regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
Disclosures of Your Personal Data
We may share your personal data with third parties including third-party service providers, regulatory bodies, and under valid court orders. In the event of a merger, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal data, would be transferred to the surviving entity in a merger or the acquiring entity. Where we do so, we will require all third parties to respect the security of your personal data and to treat it in accordance with the law.
Retention of Your Personal Data
Equisolve will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory accounting, or reporting requirements, and/or our requirements as a ‘data processor’ pursuant to applicable law (such as retaining information of our clients during the duration of our relationship with such clients).
We consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal or regulatory requirements. By law we have to keep basic information about our customers and suppliers for tax purposes for a certain period after the last transaction.
In some circumstances, you can ask us to delete your data: see the Data Rights section for further information. In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Data Controller/Data Processor Distinction
Equisolve serves as a data processor when providing its core business (e.g., the creation and maintenance of IR and brochure websites for other business entities). In other words, we process personal data on behalf of our clients and such clients serve as the data controllers.
When serving as a processor, we collect the client’s mailing list to send email communications related to press releases, webinars, and other client events to various recipients. It is our client’s obligation to ensure that such recipients have affirmatively opted-in to receiving such communications. You may opt out of those emails at any time by clicking the unsubscribe link at the bottom of such emails or as otherwise provided by our clients. We also will set up log-in credentials for client representatives to access our content management system in order to upload and manage content related to their website.
However, we are a data controller for the personal data we collect directly from individuals through the public-facing portions of Equisolve.com and business contact data of client and service provider representatives for furthering business relationships. This means that we are ultimately responsible for deciding how we hold and use your personal data when you provide it to us through this site.
Your Personal Data Rights
Under the European Union (EU) General Data Protection Regulation (GDPR), in effect from May 25, 2018, if you are located in the European Economic Area (an “EEA Individual”), you have certain rights with regard to your personal data. Equisolve must respond to a request to exercise these rights within one month.
If you would like to request details of the personal data we hold about you, please contact us at firstname.lastname@example.org.
Under the GDPR, if you are an EEA Individual, you have the following rights in regard to your personal data:
- Right to be informed – you have the right to request details of how your personal data is processed. This Privacy Notice is a proactive document designed to meet this right.
- Right to request access – you can request copies of the personal data we hold about you. This is commonly known as a “data subject access request” or DSAR.
- Right to request correction or rectification – if you think that some or all of the personal data we hold on you is incorrect or incomplete, you can ask for it to be corrected.
- Right to request erasure – you have to right to ask us to delete your personal data if you think that we do not have a legal reason to continue to process it.
- Right to request suspension of processing – this enables you to request we suspend processing your personal data; for example, while we establish the accuracy of the data.
- Right to object – you have the right to object to the processing of your personal data for direct marketing purposes.
- Right to request data portability – you can request that your personal data is transferred to a third party directly in a readable format.
In the limited circumstances where you may have been asked for, and you have provided, your consent to the collection, processing, and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another lawful basis for doing so.
You may also have the right to make a lodge a complaint to the relevant Supervisory Authority pursuant to the GDPR at any time; however, we request, at your complete discretion, that you reach out to us first at firstname.lastname@example.org to see if we can remedy such complaint before escalating to a Supervisory Authority.
Important Notice to Non-U.S. Residents
Our servers are operated in the United States. Please be aware that your Information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. Except in the case of data transfers under the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, your decision to provide such data to us, or allow us to collect such data, constitutes your consent to this data transfer.
E.U.-U.S. and Swiss-U.S. Privacy Shield Notice
Important Notice for Residents of the European Economic Area and Switzerland
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Equisolve is subject to the investigatory and enforcement powers of the Federal Trade Commission.
We provide an individual with the opportunity to opt-out before we share your personal data with third parties other than our agents, or before we use it for a purpose materially different from which it was originally collected or subsequently authorized. To request to limit the disclosure of such personal data, please submit a written request to email@example.com, with the subject line, “Privacy Shield.”
We will not disclose your sensitive personal data to any third party without first obtaining your opt-in consent and shall also obtain your opt-in consent before we use sensitive data for a purpose other than which it was originally collected or subsequently authorized.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
In compliance with the Privacy Shield Principles, Equisolve commits to resolve complaints about your privacy and our collection or use of your personal data transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Equisolve by email at firstname.lastname@example.org.
Equisolve has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Onward Transfer to Third Parties under the Privacy Shield
Equisolve’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Equisolve remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Equisolve proves that it is not responsible for the event giving rise to the damage.
Retention of Personal Information under the Privacy Shield
How We Protect Your Personal Information under the Privacy Shield
Equisolve takes very seriously the security and privacy of the personal data that it collects pursuant to the Privacy Shield. Accordingly, we will implement reasonable and appropriate security measures to protect your personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.
Under California Civil Code Section 1798.83, California residents who have an established business relationship with Equisolve may choose to opt out of our sharing their Information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Information to third parties for the direct marketing purposes, please send an e-mail to email@example.com.
In addition, Equisolve does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
If you are unhappy with how any aspect of this Privacy Notice, or how your personal data is being processed, please contact us at firstname.lastname@example.org.
If you have any questions or comments regarding this Privacy Notice or this site, please contact us at email@example.com.