OneTrust Privacy Notice

Introduction

OneTrust (“OneTrust,” “we” or “us”) offers a privacy, security and governance platform, and hosts and attends events globally. We also own and operate several websites (e.g. onetrust.com, dataguidance.com, onetrustprivacytech.com, privacyconnect.com, redacted.ai, convercent.com, converge.convercent.com) (individually, “Website” and collectively the “Websites”). This privacy notice aims to inform you about how we collect, use, disclose and store information that may identify you as an individual (“Personal Information”), when you:

• interact or use our Websites, including downloading materials from our resources page or requesting a demo,
• register and/or attend any of our events (e.g. PrivacyConnect and PrivacyTech), webinars, or the conferences we attend (collectively “Events”), and
• if you use any of our products, services or applications (including any trial) (collectively the “Services”) in any manner.

What information does OneTrust collect?

Information You Provide to Us:

From Websites or Events: We may collect identifiers that you choose to send to us or provide to us, for example, on our “Request a Demo” (or similar) online form or if you register for a OneTrust webinar. If you contact us through the Websites, we will keep a record of our correspondence.

From the Services: We receive and store information you provide directly to us. For example, when setting up new users, we collect identifiers, such as name, e-mail address, postal addresses, phone numbers, job titles, etc.; we collect also commercial information, such as records of the services purchased or demos requests. We may also collect media, documents or other information you provide to us.
Our customers will typically act as data controllers for any personal information related to them or third-parties that they upload in our systems in connection with the services. Further details can be found in the data processing agreement. OneTrust will typically act as a data processor in accordance with applicable data processing agreements.

Information We Automatically Collect:

When you use the Websites: When you visit the Websites, we collect Internet or other electronic network activity information, such as your device’s IP address, referring website, what pages your device visited, and the time that your device visited our Website. We may also rely on analytics, as further specified in our “Cookie Policy”.

When you use the Services:
Internet or other electronic network activity information may also be collected when you use the Service:

• Usage information – we keep track of user activity in relation to the types of Services our customers and their users use, the configuration of their computers, and performance metrics related to their use of the Services.
• Log information – we log information about our customers and their users when you use one of the Services including Internet Protocol (“IP”) address.
• Information collected by cookies and other similar technologies – we use various technologies to collect information which may include saving cookies to users’ computers.
• Customer Feedback – While using the Services, you may be asked to provide feedback (e.g. in the software directly or after receiving help from our support team). Providing this feedback is entirely optional.

For further information, please read the section below headed “Cookies and other Tracking Technologies”.

How and on what grounds do we use the information?

Websites or Events:

We will use the information we collect via our Websites:

• To administer our Website, our events and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
• To improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
• For trend monitoring, marketing and advertising;
• For purposes made clear to you at the time you submit your information – for example, to fulfill your request for a demo, to provide you with access to one of our webinar’s or whitepaper’s or to provide you with information you have requested about our Services; and
• As part of our efforts to keep our Website secure.

Our use of your Personal Information may be based on our legitimate interest to ensure network, information security and business performance improvement.
Our direct marketing purposes are based on your consent (for example. when you request a demo, contact us directly, provide us your business card, agree to receiving communications after an event and so on). We may also rely on our legitimate interest to improve business and marketing practices, or contact you to offer similar products and services that you might have bought from us or negotiated for with us.

Services:

We may use the information we collect from our customers and their users in connection with the Services we provide for a range of reasons, including to:

• Set up a user account,
• Provide, operate and maintain the Services;
• Process and complete transactions, and send related information, including transaction confirmations and invoices;
• Manage our customers’ use of the Services, respond to enquiries and comments, and provide customer service and support;
• Send customers technical alerts, updates, security notifications, and administrative communications;
• Investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities; and
• For any other purposes about which we notify customers and users.

We use your Personal Information in this context based on the contract that we have in place with you or our legitimate interest for security purposes and business practice improvement (e.g., the prevention and investigation of fraudulent activities). Personal Information will be deleted based on the terms of the contract. You can exercise your rights regarding your personal information by filling out this Web Form.
Provision of personal information in this instances might be necessary to enter the contract. Failure to provide such personal information might cause some services to become unavailable.

How do we share and disclose information to third parties?

We share and disclose information (including Personal Information) about our customers in the following limited circumstances:

Vendors, consultants and other service providers:

We may share your information with third party vendors, consultants and other service providers who we employ to perform tasks on our behalf.  These companies include (for example) our payment processing providers, website analytics companies (e.g., Google Analytics), product feedback or help desk software providers (e.g. Salesforce), CRM service providers (e.g., Salesforce), email service providers (e.g., SendGrid) and others.
If OneTrust receives your Personal Information in the United States and subsequently transfers that information to a third party agent or service provider for processing, OneTrust remains responsible for ensuring that such third party agent or service provider processes your Personal Information to the standard required by the applicable privacy laws, including the GDPR (see the sections below headed “Additional Information for Users in the European Economic Area (“EEA”) or in the United Kingdom (“UK”)” and “International Data Transfers”).
These transfers will be typically based on our legitimate interest or agreed upon in the contract.

Event Sponsors:

When you attend an event or webinar organized by OneTrust (such as PrivacyConnect) we ask your preferences on sharing your contact details with the event sponsor. Based on your choice, we may share your contact details (such as your name, email address, company name and phone number) with the event sponsor. If you’d like to opt-out of sharing of your details with sponsors, you can always do so either at the time of registration, or by submitting a request.

Business Transfers:

We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions and based on our legitimate interest. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

OneTrust Group Companies:

We may also share your personal data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Privacy Notice and based on our legitimate interest.
Protection of OneTrust and Others: We reserve the right to access, read, preserve, and disclose any information as necessary to comply with law or court order; enforce or apply our agreements with you and other agreements; or protect the rights, property, or safety of OneTrust, our employees, our users, or others.

Disclosures for National Security or Law Enforcement:

Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements, based on our legitimate interest or legal obligations.

For how long do we store your personal information?

We store your personal information for different periods of time depending on the category of personal information.
Some information might be deleted automatically based on specific schedules, such as marketing information. Other data, for example account information, might be retained for longer period of time based on the contract you have with us. Finally, we might further retain information for business practices based on our legitimate interest or legal purposes, such as network improvement, fraud prevention, record-keeping or enforcing our legal rights.

Security and Certifications

We use appropriate technical, organizational, and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction.
For an updated list of all our certifications and security reports please refer to the following table:

Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

Your Privacy Rights

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

Cookies

You can accept or reject cookies for our Websites through our Cookie Preference Center, accessible by clicking the “cookie settings” button in the applicable Website Cookie Notice. You can also do so by adjusting your web browser controls. Please consult the Website Cookie Notice for more information about our use of cookies on the Website and how to accept and reject them.

Marketing Communications

You can opt-out of receiving certain promotional or marketing communications from us at any time, by using the unsubscribe link in the emails communications we send, or fill out this Web Form.
If you have any account for our Services, we will still send you non-promotional communications, like service related emails.

How Can I Exercise My Data Subject Rights?

If you would like to access, review, update, rectify, and delete any Personal Information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR),  you can either click the “Exercise your Rights” link available on the top left of our Privacy Notice, or fill out this Web Form. Our privacy team will examine your request and respond to you as quickly as possible.
Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We remind you that you are also entitled to lodge a complaint with a supervisory authority. For more information, you can visit the Information Commissioner’s Officer website at www.ico.org.uk

California residents

California residents have specific rights under the California Consumer Privacy Act (‘CCPA’). For more information and to exercise your rights, please see the section headed “The California Consumer Privacy Act” below.
If you are a resident of the European Economic Area or the United Kingdom, please see the section below headed “Additional Information for users in the European Economic Area and in the United Kingdom” for further information about your privacy rights.

International Data Transfers

Personal Information you submit on the Websites or through the Services may be sent to the United States and processed by us there or in other countries, on our service providers’ cloud servers. We will always protect your information in accordance with this Privacy Notice wherever it is processed. The CookiePro Service is hosted in Microsoft Azure’s data centers in Germany. For other OneTrust Services, you may choose to have the Service hosted in the E.U. or another region.

Information for users in the European Economic Area (“EEA”) or in the United Kingdom (“UK”)

OneTrust LLC may transfer Personal Information from the EEA or the UK to the United States, including Personal Information we receive from individuals residing in the EEA or the UK who visit our Websites and/or who may use of our Services or otherwise interact with us. Please note that for individuals located in the EEA or the UK, the term Personal Information used in this notice is equivalent to the term “personal data” under applicable European and UK data protection laws.
When OneTrust LLC engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR), or ii) Standard Contractual Clauses issued by the European Commission. The European Commission has determined that the Standard Contractual Clauses provide sufficient safeguards to protect the personal data transferred outside the EU or EEA. For more information, please visit https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. OneTrust LLC also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.
Following the Court of Justice of the European Union’s invalidation of the EU-US Privacy Shield Framework in Case C-311/18, OneTrust LLC will no longer rely on the EU-US Privacy Shield as a mechanism of international data transfer until further notice.
OneTrust LLC will however remain committed to maintaining its self-certification under the EU-US Privacy Shield Principles and respect its principles, as an additional measure of protection of its users’ privacy, until further notice.
Following the opinion of the Swiss Federal Data Protection and Information Commissioner (FDPIC) of 8 September 2020, OneTrust LLC will no longer rely on the Swiss-U.S. Privacy Shield as a mechanism of international data transfer until further notice.
OneTrust LLC will however remain committed to maintaining its self-certification under the Swiss Privacy Shield Principles and respect its principles, as an additional measure of protection of its users’ privacy, until further notice.
Additional privacy measures for users in the European Economic Area (“EEA”), United Kingdom (“UK”) and Switzerland

OneTrust LLC is self-certified to the EU-US Privacy Shield Framework

Please note that, despite the Court of Justice of the European Union’s invalidation of the EU-US Privacy Shield Framework as a mechanism for transfers of personal data between the EU and the U.S. in Case C-311/18, OneTrust LLC intends to maintain its self-certification under the EU-US Privacy Shield Framework and remains committed to complying with the Privacy Shield Principles. For more information one the U.S.Department of Commerce’s continued administration of the Privacy Shield program, please visit https://www.privacyshield.gov/article?id=EU-U-S-Privacy-Shield-Program-Update.
This section sets out the privacy principles we follow with respect to transfers of Personal Information from the EEA or the UK to the United States, including Personal Information we receive from individuals residing in the EEA or the UK who visit our Websites and/or who may use of our Services or otherwise interact with us.
Please note that for individuals located in the EEA or the UK, the term Personal Information used in this notice is equivalent to the term “personal data” under applicable European and UK data protection laws.
OneTrust LLC complies with the EU-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries and the UK. OneTrust LLC has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability with respect to such personal information. If there is any conflict between the policies in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
To learn more about the Privacy Shield program, see the US Department of Commerce’s Privacy Shield website located at https://www.privacyshield.gov. To view our certification on the Privacy Shield list, please visit https://www.privacyshield.gov/list.
In compliance with the EU-U.S. Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your Personal Information. Individuals located within the EEA or the UK with inquiries or complaints regarding this Privacy Notice should first contact OneTrust at: Andrew Clearwater, VP of Privacy,[email protected].
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of personal data within 45 days of receiving your complaint. OneTrust LLC has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and 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.
Under certain limited circumstances, individuals in the EEA or the UK may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution (discussed above) have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/.
OneTrust LLC is subject to the jurisdiction of the U.S. Federal Trade Commission for purposes of Privacy Shield enforcement.
Please note that OneTrust LLC is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

OneTrust LLC is self-certified to the Swiss-U.S. Privacy Shield Framework

Please note that despite the opinion of the Swiss Federal Data Protection and Information Commissioner (FDPIC) of 8 september 2020, OneTrust LLC intends to maintain its self-certification under the Swiss Privacy Shield Framework and remains committed to complying with its Principles. For more information one the U.S. Department of Commerce’s continued administration of the Swiss Privacy Shield program, please visit https://www.privacyshield.gov/article?id=Swiss-U-S-Privacy-Shield-FAQs
We comply with the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
In compliance with the Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. Swiss individuals with inquiries or complaints regarding this Privacy Notice should first contact OneTrust at: Andrew Clearwater, VP of Privacy, [email protected].
OneTrust has further committed to refer unresolved privacy complaints under the Swiss-US 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 http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Under certain limited circumstances, individuals in Switzerland may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution (discussed above) have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/.

Additional information for California Consumers – The California Consumer Privacy Act

Under the California Consumer Privacy Act (‘CCPA’), California residents have certain rights regarding the personal information that businesses have about them. This includes the rights to request access or deletion of your personal information, as well as the right to direct a business to stop selling your personal information.

Personal Information disclosed for Business Purposes.

OneTrust shares and has shared in the preceding 12 months personal information as necessary for certain “business purposes,” as defined by the CCPA (Cal. Civ. Code 1798.140(d)) and specified in section “How do we share and disclose information to third parties?” This includes sharing identifiers, commercial information and internet or other electronic network activity with providers of payment processing, customer relationship management, consulting, email, product feedback and helpdesk services.
While OneTrust does not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). This includes sharing identifiers, commercial information and internet or other electronic network activity with advertising networks, website analytics companies, and event sponsors.
OneTrust does not sell information of consumers under 16 years of age.

California Consumer Privacy Act Rights

Right to Opt-out of Sale

While OneTrust does not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). We support the CCPA and wish to provide you with control over how your personal information is collected and shared.
You have the right to direct OneTrust to not sell your personal information. Click here to learn more and to exercise your right to opt-out.
With respect to cookies, you can always customize your settings at any time.
Please note that we may still use aggregated and de-identified personal information that does not identify you or any individual; we may also retain information as needed in order to comply with legal obligations, enforce agreements, and resolve disputes.

Right to Request Disclosure

You have the right to request disclosure about what categories of personal information OneTrust has sold or disclosed for a business purpose about you and the categories of third parties to whom the personal information was sold or disclosed. Additionally, you have the right to request disclosure of specific pieces of information. Below is a full list of the information that you can include in your request.

• The categories of personal information that OneTrust has collected about you.
• The categories of sources from which OneTrust collected the personal information.
• The business or commercial purpose for collecting or selling the personal information.
• The categories of third parties with whom OneTrust shares personal information.
• The specific pieces of personal information OneTrust has collected about you.
• The categories of personal information that OneTrust disclosed about you for a business purpose.
• The categories of personal information that OneTrust has sold about you, as well as the categories of third parties to whom OneTrust sold the information

If you would like to exercise your right to request disclosure, please fill out this request form. Our privacy team will examine your request and respond to you as quickly as possible.

Right to Request Deletion

You have the right to request that OneTrust delete any personal information about your that OneTrust has collected from you. Please note that there are exceptions where OneTrust does not have to fulfil a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation.
If you would like to exercise your right to delete, please fill out this request form. Our privacy team will examine your request and respond to you as quickly as possible.

The Right to Non-Discrimination

OneTrust will not discriminate against you (e.g., through denying goods or services, or providing a different level or quality of goods o/r services) for exercising any of the rights afforded to you.

How do we handle your requests?

We endeavour to respond to a verifiable consumer request within the required timeframes. If we require more time, we will inform you of the reason and extension period in writing.
If you submit your privacy request with us electronically via our Privacy Webform, we will deliver our written response to the verified email associated with the request. If you did not submit the request with us via the online webform, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

California and Delaware “Do Not Track” Disclosures

California and Delaware law require OneTrust to indicate whether it honor’s “Do Not Track” settings in your browser concerning targeted advertising. OneTrust adheres to the standards set out in this Privacy Notice and does not monitor or respond to Do Not Track browser requests.

Children

We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Information, please contact us at [email protected]

Linked Websites

For your convenience, hyperlinks may be posted on the Websites that link to other websites (the “Linked Sites”). We are not responsible for, and this Privacy Notice does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on the Websites. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read the privacy notice of each Linked Site that you visit to understand how the information that is collected about you is used and protected.

Changes to the Privacy Notice

We’re constantly trying to improve our Websites and Services, so we may need to change this Privacy Notice from time to time as well. We will alert you to material changes by, for example, placing a notice on our Websites and/or by sending you an email (if you have registered your e-mail details with us) when we are required to do so by applicable law. You can see when this Privacy Notice was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Privacy Notice.

Contact Us

For Customers: Please contact the OneTrust entity identified in your order form.
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