Last Updated: April 20, 2023
The Types and Categories of Personal Information We Collect
|Personal Information Category||Example|
|Personal identifiers||Name, alias, signature, postal or shipping address, phone number, date of birth, unique personal identifier, online identifier, email address, internet protocol (IP) address, state identification card number, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.|
|Registration Data||Information provided when you register for an account to use our Services or features on our Site, including usernames and passwords.|
|Business Contact Data||Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.G., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities (e.G., visitor logs or registries).|
|Information with respect to your marketing preferences and your subscriptions to our publications or other offerings, including feedback and survey responses.|
|Service or Product|
|Information provided when you use or participate in any of our Services or|
offerings other than Registration Data. Information an individual provides
when visiting a physical location or premise, or interacting with a
representative, of SAI Group (e.g. workshops, conferences, trade show booths
or similar interactions).
|If you apply for a job with us, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references. (For more information, see “Employment Applications and Workforce Management” below).|
|Biometric information||WE DO NOT COLLECT – Fingerprint, voice print, retinal print, scan of hand or facial geometry.|
|Information from multimedia||Audio, electronic, visual or similar information.|
|Internet or other electronic network activity information||Browsing history, search history, information regarding your interaction with our site, applications or advertisements, linking behavior, web pages you visit while visiting our site or applications, browser type, internet service provider (isp), cookies, and mobile device information including device identifier or other information. (for more information, see “technical data and cookies” below).|
|Geolocation data||WE DO NOT COLLECT – Physical location, movements, or trip tracking information.|
|Inferences||Profile data reflecting preferences, characteristics, psychological trends,|
predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
We do not collect or process sensitive personal information (for example, your social security number, financial account information, your precise geolocation data, or your genetic data), and you agree not to provide us with sensitive personal information.
Technical Data and Cookies
When you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, and your experience on the Site and other websites, including the following:
Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.
Sources of Information
We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using the Site, and from third parties including publicly available sources. More specifically, we collect personal information from the following sources:
First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., account registration, completing purchases, signing-up for subscriptions) or whenever you directly engage with us, such as when you interact with us, such as through conferences, workshops, trade shows or other events or contacts, when you visit our offices or premises or otherwise contact us.
Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data and Cookies” above).
Third-Party Sources. We collect personal information from third parties, such as publicly available databases, directories, social networking providers, advertising companies, our service providers, and third-party references.
How We Use your Personal Information / Purpose of Collection
We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our legitimate business interests, including to (i) provide, operate, maintain, improve, and promote our Services, (ii) enable you to access and use our Services, (iii) process and complete transactions, and send you related information, including purchase confirmations and invoices, (iv) send transactional messages (e.g., responses to your comments, questions, and requests) and provide customer service and support for our Services, (v) furnish technical notices, updates, alerts, and support and administrative messages to you, (vi) provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, and events), (vii) monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests (e.g., marketing), (viii) investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities, and (ix) personalize our Services, including providing features or advertisements that match your interests and preferences. Notwithstanding the foregoing, we may collect and use your personal information for any other purpose for which we obtain your consent. For the avoidance of doubt, you hereby agree that we may contact you via any means, including SMS/text message and email, to furnish you information regarding a contract or agreement with us or similar data and information pertaining to a commercial transaction.
Sharing Information / Third-Party Disclosures
We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for purposes unrelated to our Services.
- Intra-Group. We may share your personal information within the affiliates and business divisions of SAI Group to support our business practices and in the event SAI Group entities act as “service providers” to other SAI Group affiliates or subsidiaries.
- Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions, tracking and responding to customer questions or complaints, and performing analyses to improve the quality of our Services.
- Business Partners. We may share your personal information with third parties that help promote or provide our Services and marketing materials.
- Customers and Prospects in Connection with our Services. We may share your personal information with other of our customers and prospects in connection with our Services. For example if we have lawfully included your personal information in a database of subject matter experts, we may provide appropriate information to a customer who has engaged us to identify referrals having your subject matter expertise for their legitimate business interests in connection with their use of our Services.
- Business Sales or Restructurings. Circumstances may arise where for strategic or other business reasons we decide to sell, buy, divest, merge or otherwise reorganize our business in whole or in part. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of such business.
- Security; Business Interests; Legal. We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, we may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests.
- Consent. We may also disclose your information upon your express consent for the purpose such consent was provided. In the event that you facilitate a transaction with us, or request information from or otherwise engage with us, and such activities require us to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct us to intentionally disclose your personal information to the service provider or third party.
Opt-Out Rights / Do Not Sell My Personal Information
Links to Other Websites; Your Direct Third-Party Disclosures
a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.
Data Retention, Localization and Transfer
Where required by applicable law, international transfers take place only when there is an adequate level of protection to the fundamental data protection rights of individuals. In some circumstances, we may choose to rely upon an adequacy decision to lawfully transfer personal information. Standard contractual clauses (“SCCs”) are one of several mechanisms that allow for personal information to be transferred across jurisdictional borders and we may rely on these for transfers to and from our affiliates, vendors and business partners where applicable. In general, we have no reason to believe that the laws and practices in the country of destination applicable to the processing of the personal information by the data importer, including any requirements to disclose personal data or measures authorizing access by public authorities, prevent the data importer from fulfilling its obligations under the SCC or other applicable mechanisms. Where required by applicable law, an assessment of that belief is made on a case-by-case basis. Please contact us to request a copy of our appropriate safeguards.
We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. No information system can be fully secure and we cannot guarantee the absolute Security of your personal information. Moreover, we are not responsible for the security of personal information you transmit to the site and/or the services over networks that we do not control, including the internet and wireless networks, and you provide us with any personal information and data at your own risk. To the extent permitted by law, we shall not be liable or otherwise responsible for any data incident or event that may compromise the confidentiality, integrity, or security of your personal information. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to our services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.
No Data Collected from Children
You are permitted, and hereby agree, to only provide personal information to us if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO US, YOU EXPRESSLY REPRESENT AND WARRANT TO US THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE US WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT THE USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY US FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO US.
Updating Your Information
It is important that your personal information is accurate and reliable. In certain circumstances, the Site or our Services may provide you the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email). Please update such information when such changes are warranted. If the Site or Service does not contain such features, please directly notify us of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.
Email Marketing and Your Rights
You have the right to opt-out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing via our interactive webform or by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify us, in writing, of any change to the email address to which you subscribed or consented to receive email marketing from us. Note that exercising your right to unsubscribe or opt-out of receiving email marketing communications will not affect other processing activities that may be lawfully undertaken with respect to your personal information.
California Privacy Rights
Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents have additional data privacy rights, including the following:
- Access: The right to access general categories and/or the specific pieces of personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months, including the sources from which the personal information was collected; the business or commercial purpose for which your personal information was collected, used, disclosed, or sold; and the third parties with whom we have shared your personal information.
- Deletion/Correction/Erasure: The right to request that we delete/erase your personal information under certain circumstances, and/or correct personal information that is inaccurate.
- Data Portability: The right to request that we transfer, to the extent technically feasible, personal information in certain forms and formats.
- Nondiscrimination: The right not to be subject to discrimination for asserting your rights under the CCPA.
To exercise any of the CCPA’s data privacy rights set forth herein, please contact us in accordance with the “Contact Us” section listed below. If you would prefer, you may designate an authorized agent to submit a CCPA privacy request on your behalf. An authorized agent must be registered with the California Secretary of State to conduct business in California.
Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information under the CCPA, we will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. we will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email or other means and match at least two pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute and are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see: https://oag.ca.gov/privacy/ccpa.
Third-Party Marketing. We do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes unrelated to our Services. If you have any questions or concerns about our marketing, please contact us in accordance with the “Contact Us” section listed below.
Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.
Persons with Disabilities
Employment Applications and Workforce Management
Events; Video Teleconferencing; Support Services; Recordings
SAI Group hosts and uses video teleconferencing platforms, text messaging, and telephone capabilities to facilitate conferences, workshops, meetings, training events, customer support, and other programs. We often use online platforms and solutions that are owned and administered by a third-party service provider (e.g., MS Teams, Google, Zoom, WebEx, Skype for Business). Please be aware that our Site, Services, and video teleconferencing and telephone customer support capabilities may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By using our Site, or participating in our video teleconferencing or telephone customer support capabilities, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.
Changes to the Policy
If you have questions regarding this Agreement or your access or use of the Sites governed by this Agreement, would like to make a data subject request or exercise any of your rights described above, or request more information from us, please contact us by: (email) [firstname.lastname@example.org]; (telephone) [+1 (610) 685-4200]; or (mail) Privacy Officer at 4970 DeMoss Road, Suite 300, Reading, PA 19606, USA. EU data subject may also submit a data subject request by: (email) [email@example.com]; (telephone) at [List local Data Protection Officer Contact]; or (firstname.lastname@example.org) Data Protection Officer at [List local Data Protection Officer Contact].