HEMISPHERE GNSS, INC. PRIVACY POLICY
Effective October 17, 2018

  1. HEMISPHERE GNSS IS COMMITTED TO PROTECTING YOUR PRIVACY

Hemisphere GNSS, Inc. (‘Hemisphere’, ‘our’, ‘us’, or ‘we’) owns, operates, and is the controller responsible for the following (‘Services’):

This Privacy Policy was designed to inform you (‘User’) of how we collect, use, and disclose your personal data/information (‘Personal Information’) when you use our Services. Your Personal Information is information about you or that is associated with you.

We take the privacy and security of your Personal Information very seriously. We will never use or share your information with anyone except as described below in this Privacy Policy.

  1. PERSONAL INFORMATION

2a. What Information We Collect

Through our Services we collect User’s Personal Information only when they voluntarily provide it via one of the methods below:

  • Filling-out and submitting online forms (e.g. ‘Contact Us’, etc.);
  • Subscribing to ‘Compass’ newsletter or other marketing services;
  • Registering for our Technical Support Service Desk;
  • Registering for our Atlas® Customer Portal;
  • Emailing employees within our company;
  • Filling-out and submitting online surveys; and
  • Participating with our social networking platforms (e.g. Facebook, LinkedIn, Twitter, YouTube, etc.).

Personal Information that may be collected (but not limited to) is:

  • Name and surname;
  • Email address;
  • Mailing address;
  • Phone number (business and/or mobile);
  • Job title; and
  • Company name

If you do not want us to collect and/or process your Personal Information, please do not share it with us.

2b. How We Use Your Personal Information

The information we collect from you which has been voluntarily provided by Users, may be used in the following ways (but not limited to):

  • Tailor Your Experience: Your information allows us to better respond to your individual needs;
  • Improvement of Our Services: We always strive to improve our Services based on the information and feedback we receive from Users;
  • Improve Customer Satisfaction/Support: Your information allows us to improve our overall customer satisfaction and customer service requests;
  • Marketing Emails: In order for you to receive periodic marketing related emails, such as our ‘Compass’ newsletter, you must affirmatively opt-in to receive these emails. If at any time you no longer wish to receive these emails, you can unsubscribe, be removed, or opt-out via the link located at the bottom of these emails or email web@hgnss.com and inform us that you no longer wish to receive these emails; and
  • Service Issues/Updates: Contacting you about sale, service, or warranty issues and updates.

2c. Legal Basis for Processing in the European Union

In the European Union (‘EU’), the purposes for which we process your Personal Information are:

  1. The provision of Personal Information by you may be necessary for the performance of any contractual relationship we have with you;
  2. Where it is necessary for compliance with our legal obligations laid down by EU law; and
  3. Where in our legitimate interests (provided these are not overridden by your interests and fundamental rights and freedoms – this includes our own legitimate interests and those of other entities and branches in our group of companies) such as:
  • to contact you and respond to your requests and inquiries;
  • for business administration, including statistical analysis;
  • to provide the Services to you;
  • for fraud prevention and detection; and
  • to comply with applicable laws, regulations, or codes of practices.

The table at ANNEX 1 (below) sets out the categories of data we collect about you and how we use such information. The table also lists the legal basis which we rely on to process the Personal Information and the applicable retention periods.

2d. How We Share Your Personal Information

We do not sell your Personal Information to third-parties. We may however share Personal Information with our business partners in order to improve your experience. For instance, if you are inquiring about purchasing a product in a certain region, we will share your information with that region’s local dealer/distributor.

We may share non-personally identifiable visitor data/information to other parties for analytical, marketing, statistical, or other uses.

We reserve the right to use or disclose any information without notice or consent as needed to satisfy any law, regulation, or legal request; to conduct investigations of consumer complaints or breaches of the law; to protect the integrity of our Services, rights, and our property; or to cooperate in any legal investigation.

In the EU, we share your Personal Information with the recipients set out in ANNEX 1.

2e. How We Keep Your Personal Information Safe and Secure

We take the privacy of your Personal Information very seriously and employ reasonable, commercial precautions to protect all information from destruction, disclosure, loss, modification, tampering, and unauthorized access.

To ensure the protection of Personal Information collected and processed, we employ the following physical, organizational, and technological security safeguards:

  • Access to our Services and servers containing Personal Information is limited to designated employees, authorized third-parties working with us and on our behalf, to our Internet Service Provider (‘ISP’), and other authorized individuals;
  • Our servers contain firewall protection;
  • Our Services all use Secure Socket Layer (‘SSL’) technology and are encrypted; and
  • All employees are made aware of the importance of maintaining the confidentiality and privacy of our Users’ Personal Information.

Please be aware that no method of transmission over the internet is 100% safe or secure, and we are unable to guarantee the absolute security of the Personal Information which we have collected.

The length in which we retain your Personal Information and our retention periods of such information are based on business needs, and once your information is no longer needed, used, or you request removal, we will irreversibly and securely destroy it.

  1. EXTERNAL/THIRD-PARTY LINKS

Our Services may contain links or URLs to external or third-party websites. If you click on these links and are redirected to external websites, we no longer assume responsibility or control over said websites. These external websites do not fall under this Privacy Policy and any Personal Information that you provide while on external websites are governed by their own policies and terms & conditions.

This Privacy Policy applies only to our Services and we recommend that you review the policies and terms & conditions of each external website you visit when redirected from our Services carefully.

We have no control over, and assume no responsibility for the content, policies, and terms & conditions of external or third-party websites.

  1. CHILDREN’S PRIVACY

We do not knowingly collect any Personal Information from any individuals under the age of sixteen (‘child’ or ‘children’) without the consent of their parent or guardian. Our Services, products, solutions, and technologies are all directed and marketed to individuals who are at least sixteen years of age or older.

If you are a parent or guardian and know that your child or children have provided us with any of their Personal Information, please contact us. If it becomes known to us that a child has provided Personal Information without the consent of a parent or guardian, we will take measures to permanently delete and remove the information from our servers.

  1. COOKIES

Cookies are files that contain small amounts of data, which may include an anonymous unique identifier and other non-personally identifiable information. Information collected includes (but not limited to):

  • date and time of access;
  • IP (Internet Protocol) address;
  • ISP;
  • browser type and version;
  • URL of referring website; and
  • pages accessed

Cookies are sent to your browser via a website and transferred to your device. It is not possible for us to assign this data to a specific person.

Cookies allow us to provide you with better Services and User experience. It allows us to monitor pages that Users find most helpful and which are not. Cookies do not give us access to your computer or any information about you, other than the data you choose to share with us by allowing Cookies to be tracked.

For more information on how we use Cookies, please read our Cookies Policy here.

  1. STOP CONTACT

If you have previously subscribed to one of our mailing services or marketing emails (which may include but is not limited to, ‘Compass’ newsletter) and you no longer wish to receive them, you may unsubscribe, be removed, or opt-out at any time via a link at the bottom of such mailing services or marketing emails. If, for some reason, your efforts to unsubscribe, be removed, or opt-out are unsuccessful, please send a request to web@hgnss.com for removal.

Additionally, you are generally able to opt-out of ad network placements of Cookies or targeted advertising by visiting the following external links:

  1. CHANGES TO THIS PRIVACY POLICY

We reserve the right to amend, change, and update this Privacy Policy periodically and without notice. We encourage you to review our Privacy Policy whenever you use our Services to see if the policy has been amended, changed, or updated.

  1. YOUR RIGHTS AND HOW TO CONTACT HEMISPHERE

Your Personal Information is only used for the purposes outlined above in this Privacy Policy and will never be rented, shared, or sold to any third-party.

If you are located in the EU or Switzerland, you have the following rights in respect to your Personal Information that we hold:

  • Right of Access: The right to obtain access to your Personal Information;
  • Right to Rectification: The right to obtain rectification of your Personal Information without undue delay where that Personal Information is inaccurate or incomplete;
  • Right to Erasure: The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed;
  • Right to Restriction: The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information;
  • Right to Portability: The right to portability allows you to move, copy, or transfer Personal Information easily from one organization to another; and
  • Right to Object: You have a right to object to processing based on legitimate interests and direct marketing.

If you wish to exercise any of these rights, please contact us using the contact details at the end of this Privacy Policy.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

If you have any questions or concerns about this Privacy Policy, or to exercise your rights per the above, please send your request in writing by mail or email to:

HEMISPHERE GNSS, INC.

Privacy Officer
8515 E. Anderson Drive
Scottsdale, AZ 85255, USA
Email: privacyofficer@hgnss.com

Please be aware that any emails sent may not be encrypted.

ANNEX 1

Category of Personal Information Why We Use It Legal Basis for Processing Categories of Recipients Retention Period
Contact information and basic personal details such as your name and surname, email address, mailing address, and phone number (business and/or mobile). We use this information to:

· provide you with the Services;

· communicate with you;

· send information to you about updates to the Services (e.g., about sale, service, or warranty issues), and any news, alerts and marketing communications (in line with your settings and options) such as our ‘Compass’ newsletter, you must affirmatively opt-in to receive these emails. If at any time you no longer wish to receive these emails, you can unsubscribe, be removed, or opt-out via the link located at the bottom of these emails or email web@hgnss.com and inform us that you no longer wish to receive these emails; and

· deal with inquiries and complaints made by or about you relating to the Services.

The processing is necessary for:

· the performance of a contract and to take steps prior to entering into a contract; and

· our legitimate interests, namely providing the Services, for marketing purposes, and communicating with Users.

As required in accordance with how we use it, we will share your Personal Information with the following:

· Service Providers and Advisors: Third-party vendors and other service providers that perform services for us, on our behalf, which may include selling of our products and/or services, providing payment, mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting, or analytic services;

· Purchasers and Third-Parties in Connection with a Business Transaction: Personal Information may be disclosed to third-parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business; and

· Law Enforcement, Regulators, and Other Parties for Legal Reasons: Third-parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of the Services; and/or (c) exercise or protect the rights, property, or personal safety of Users of the Services, or others.

For no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.
Employment information such as your job title and company name. We use this information to:

· provide you with the Services; and

· communicate with you.

The processing is necessary for:

· the performance of a contract and to take steps prior to entering into a contract; and

· our legitimate interests, namely providing the Services.

Correspondence, Comments, and Opinions:

When contacting us via online forms (e.g. ‘Contact Us’, etc.) or by email, your comments, opinions, and instructions may be recorded.

We use this information to:

· address your questions, issues, and concerns;

· improve the Services;

· determine products and Services that may be of interest to you;

· send you marketing communications in accordance with your marketing preferences;

· improve our communications and staff training; and

· improve customer support/satisfaction: Your information allows us to improve our overall customer satisfaction and customer service requests.

The processing is necessary for:

· the performance of a contract and to take steps prior to entering into a contract; and

· our legitimate interests, namely providing the Services.

Start typing and press Enter to search