Effective of 14 July 2020
Table of Contents
- who is the data controller under this policy and how you can contact us
- what information we may collect and process about you
- how we may obtain your personal information
- how we may use your personal information
- on what basis we use your personal information
- how long we store your personal information
- how we may share your personal information with third parties
- which countries we may transfer your personal information to
- links, third-party services and websites
- data security
Please read this policy carefully to be clear how Brandsfield will treat your personal information.
WHO IS THE DATA CONTROLLER UNDER THIS NOTICE AND HOW YOU CAN CONTACT US?
BRANDSFIELD LLC (collectively, “Brandsfield”, “we”, or “our”) is a controller of your personal data.
If you have any questions or concerns regarding our treatment of your personal data, please contact us at: email@example.com. Our office location is 1-A Sportyvna Square, “Gulliver” business center, tower B, 11th floor Kyiv, 01001, Ukraine.
WHAT INFORMATION WE MAY COLLECT AND PROCESS ABOUT YOU?
We obtain information about you through the means discussed below when we provide the Services, including through your use of our website; when you communicate with us via email or other channels; when you sign up for a newsletter, webinar, meeting, conference, or event. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use the Services.
The personal information that we may collect and process includes:
- Basic information, such as your name (including name prefix or title);
- Contact information, such as your email address and phone number(s);
- Technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically.
HOW WE MAY OBTAIN YOUR PERSONAL INFORMATION?
Personal information you provide to us
You may provide a variety of information about yourself to us, such as your name, email address, postal mailing address, telephone number; upload, purchase, view, or download certain content or products from the Services; or otherwise use the features and functionality of the Services.
Information we may collect automatically
Visiting our website does not require you to provide any personally identifiable information, such as your name, address, e-mail address or phone number. When you visit our website, we automatically collect certain information, which, however, does not allows us to identify you. This information may include the following:
Brandsfield collects information about the websites’ content mostly viewed by the visitors, frequency of the connections to the website, software and hardware exploited to visit our website, geography of our visitors. This information enables Brandsfield to understand the manner how the visitors work with our website. In order to obtain such information we employ Google Analytics (the detailed information about this tool is available here). You may disable any data collections by this tool at your discretion as instructed here.
We rely on our legitimate interest to provide customized services and better our content when collecting your browsing statistics.
The hardware of our website hosting provider may record requests made by the visitors to the website, the information on software and hardware exploited to visit our website, IP address assigned as well as timing related to access. We use this information to enhance the security of our website.
We rely on our legitimate interest to ensure security of our website when collecting your logs data.
Information we collect from other sources
We may receive information about you from other sources, including third parties that help us: update, expand, and analyze our records; identify new customers; or prevent or detect fraud. We may also receive information about you from social media platforms including but not limited to when you interact with us on those platforms or access our social media content. The information we may receive is governed by the privacy settings, policies, and/or procedures of the applicable social media platform, and we encourage you to review them.
HOW WE MAY USE YOUR PERSONAL INFORMATION?
Brandsfield collects and processes personal information about you in a number of ways, including through your use of our website and in the provision of Services by us. We use that information to:
- communicate with you, including to respond to your requests.
- provide you with the Services.
- provide and improve this website, including auditing and monitoring its use.
- manage and administer our relationship with you, including to notify you of major Services updates, for customer service purposes or contact you regarding any content that you have posted to or downloaded from the Services.
- periodically promote the Services, including sending updates, newsletters, legal alerts, publications and details of meetings, events, and seminars. If you want to stop receiving promotional materials, you can follow the unsubscribe instructions at the bottom of any email from us.
- fulfil our legal, regulatory obligations, including establishing, exercising or defending legal claims; protecting your, our, or other’s rights.
We may also ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing your personal information for a specified purpose, you have the right to withdraw your consent at any time and we will stop processing of your data for that purpose.
ON WHAT BASIS WE USE YOUR PERSONAL INFORMATION?
We use your personal information on the following legal grounds:
- to perform a contract with respect to providing the Services.
- for the establishment, exercise or defense of legal claims or proceedings.
- to comply with legal and regulatory obligations.
- for legitimate business purposes. Please see ‘How we use your personal information’ for more detail.
- your consent.
HOW LONG DO WE STORE YOUR PERSONAL INFORMATION?
Brandsfield will retain collected personal information as long as necessary to fulfil the purposes for which it was collected and processed. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data collected, the purposes for which we process personal data and whether we can achieve those purposes through other means and applicable legal requirements.
Upon expiry of the applicable retention period, we will securely destroy personal data collected.
HOW WE MAY SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES?
We may share your personal information with certain third parties in accordance with contractual arrangements in place with them, including:
- auditors, potential transaction partners.
- IT service providers to Brandsfield, including providers of cloud services, website hosting, maintenance, and security services;
- third parties engaged in the course of the Services we provide to you and other customers and with their prior consent, such as legal counsels and technology service providers like data room services.
- third parties involved in hosting or organizing meetings, events or seminars.
Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavors to notify you before we do this, unless we are legally restricted from doing so.
Brandsfield also reserves the right to disclose information that we believe, in good faith, is appropriate or necessary to protect Brandsfield from potential liability or from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims, or allegations; protect the security or integrity of the Services; or protect the rights, property, or safety of Brandsfield, our users, or others.
If in the future we re-organise or transfer all or part of our business, we may need to transfer your information to new Brandsfield’s entities or to third parties through which the business of Brandsfield will be carried out.
We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.
WHICH COUNTRIES WE MAY TRANSFER YOUR PERSONAL INFORMATION TO?
The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws including without limitation EU standard contractual clauses.
WHAT YOUR RIGHTS AND CHOICES UNDER THIS POLICY?
You may decline to share certain information with Brandsfield, in which case Brandsfield may not be able to provide to you some of the features and functionality found on the Services. To learn more about how you can exercise your privacy choices, including to review, update, delete, or otherwise limit Brandsfield’s use of information that you have provided directly to Brandsfield, you may contact firstname.lastname@example.org. In your request, please include your email address, name, address, and telephone number and specify all relevant background. To protect your privacy and security, we may take steps to verify your identity before granting you access or making corrections to your information.
Residents of the EEA can exercise certain data subject rights available to them under applicable data protection laws. We will comply with requests to exercise these rights in accordance with applicable law. Please note that in some circumstances, we may need to keep processing your information for certain legitimate interests or to comply with a legal obligation. Contacting us via e-mail at email@example.com you may exercise your right to:
- request access to your personal data and request information in relation to its processing;
- request rectification of your personal information;
- request erasure of your personal informaiton;
- request restriction of processing of your personal information;
- object to the processing of your personal informaiton;
- withdraw your consent (if any is given);
You may exercise your rights in accordance with applicable data protection laws.
If personal data is erased at your request, Brandsfield will only retain such copies of the information as are necessary to protect our or third party legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have entered into with Brandsfield.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see ‘How we use your personal information’) or that you may not be able to make use of the Services and products offered by us.
LINKS, THIRD-PARTY SERVICES AND WEBSITES
Brandsfield uses a variety of managerial, technical, and physical measures to protect the integrity and security of your information. These measures may vary based on the sensitivity of your information. However, no security precautions or systems can be completely secure. We cannot ensure or warrant the security of any information you transmit to Brandsfield, and you do so at your own risk. We cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
CHANGES TO THIS POLICY
We reserve the right to update this policy from time to time. Therefore, we encourage you to periodically review this page. If we make any material changes in the way we collect, use, and/or share the personal information that you have provided, we will notify you by posting notice of the changes in a clear and conspicuous manner on the Brandsfield’s website.