EFFECTIVE DATE: July 24, 2018
1. THE INFORMATION WE COLLECT ABOUT YOU
We collect information about you directly from you through your use of our Platform and Tools. The information we collect from you depends on how you use our Platform and Tools, but it will include:
Information provided by you directly
- Common identifiers, being your first and/or last name and initials;
- An email address for login purposes; and
- Contact information, including email address and phone number.
We also collect certain metadata that is being provided by you to the Platform including: name of experiments, names of datasets, remarks on experiments and other metadata that is being attached to the raw data for the purpose of providing support. It may be possible to infer personal information about you from this metadata, particularly when it is combined with other data that we hold.
Information We Collect Automatically. We automatically collect information about your use of our Platform and Tools through cookies, web beacons, and other technologies, including tracking tools, device identifiers (machine, browser and OS type), your IP address, and your geo-location based on the IP address and details regarding date and time of access to the Platform and Tools. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
2. HOW WE USE YOUR INFORMATION
We use your information, including your personal information, for the following purposes:
- to authenticate logins or to fulfill requests to send emails to allow token reset for login.
- to complete transactions.
- to send administrative information, e.g., information regarding the Platform and Tools and changes to our terms, conditions, and policies.
- for marketing purposes, including direct marketing.
- to identify trends in the use of our Platform and Tools and analyze the effectiveness of our communications.
- to develop new products and services.
- to enhance, improve, or modify our products and services.
- to validate users’ ability to access or use certain products or services.
- to comply with legal obligations, as part of our general business operations, and for other business administration purposes.
- where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Policy.
3. HOW WE SHARE YOUR INFORMATION
We may share your information, including personal information, as follows:
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
- Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
- Marketing and Analytical Tools. We share information with third parties to aid us in performing our analytics and marketing.
We also disclose information in the following circumstances:
- Business Transfers. If we are or may be acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy or insolvency proceeding, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal processes, such as in response to a court order or a subpoena.
- Aggregate and Anonymous Information. We may take user information and have it aggregated and anonymized which we refer to as “de-identified information”. We share de-identified information with third parties who may use it for our or the third party’s own marketing, advertising, research or similar purposes. Such de-identified information does not in any way identify any individual user.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Platform and Tools, while others are used to enable a faster log-in process or to allow us to track your activities on our Platform and Tools. For a list of the cookies that we use, please see our separate cookies policy available here
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies, some features of our Platform and Tools may not function.
Clear GIFs, pixel tags, and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on the web or mobile application pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Platform and Tools to, among other things, track the activities of Platform users, help us manage content, and compile statistics about usage of our Platform and Tools. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Do Not Track. Currently, whilst you are on our Platform and Tools, our systems will not recognize browser “do-not-track” requests; however, we do not track your activities after you leave our Platform. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. If you are in the EU, you may opt-out of certain third-party cookies that we and other websites may use for targeted advertising through the European Interactive Digital Advertising Alliance (EDAA) Your Online Choices Page or www.aboutads.info.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Platform, Tools or on other websites.
5. THIRD-PARTY LINKS
Our Platform and Tools may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
6. SECURITY OF YOUR PERSONAL INFORMATION
We have implemented industry-standard precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee absolute security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
7. DIRECT MARKETING
Where we have permissions or are permitted by law, we may send periodic promotional emails to you. You may opt-out of promotional and targeted (customized) direct marketing communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.
8. CHILDREN UNDER 16
Our Platform and Tools is not designed for children under 16. If we discover that a child under 16 has provided us with personal information, we will delete such information from our systems and close that account/registration.
9. INFORMATION FOR EU INDIVIDUALS
The Data Controller of the information collected through the Platform and Tools is Missinglink.AI which is headquartered in the United States at 665 Clyde Avenue, Mountain View, CA 94043. Missinglink.AI is affiliated with Samsung Electronics America, Inc. If you are a European resident who uses our products and services, you may exercise any rights permitted under the new European privacy law known as General Data Protection Regulation or GDPR. If you are a resident of any country in the European Economic Area (EEA), please visit https://www.europe-samsung.com/gdpr/webform/uk for more information about the privacy choices and rights that may be available to you.
The legal bases for using your Personal Information. We collect your information as a data controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:
- Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you. This applies to our processing activities described at 2A, 2B, 2C, and 2H above.
- Our use of your personal information is in our legitimate interest as a commercial organization to make improvements to our products and services and to grow and expand our business. This applies to our processing activities described at 2D (save where we need consent by local law), 2E, 2F, and 2G.
- Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have in particular, where we are required to disclose personal information to a court, tax authority or regulatory body in the event of an investigation. This applies to our processing activities described at 2I and 2J.
- Our use of your personal information is in accordance with your consent. This applies to our processing activities described at 2D (where required by local law).
If you would like to find out more about the legal bases on which we process personal information, please contact us using the details below.
Your Legal Rights. Subject to certain exemptions, and dependent upon the processing activity we are undertaking, European Union individuals have certain rights in relation to personal information:
- Right to access, correct, and delete your personal information: You have the right to request access to the personal information that we hold about you and: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred. You also have the right to request that we correct any inaccuracies or delete your information. We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.
- Right to restrict the processing of your personal information: You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests verification as to whether we have a compelling interest to continue to use your data. We can continue to use your personal information following a request for a restriction, where: (a) we have your consent; or (b) to establish, exercise or defend legal claims; or (c) to protect the rights of another natural or legal person.
- Right to data portability: To the extent that we process your information (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.
- Right to object to the processing of your personal information: You can object to any processing of your personal information which has our legitimate interests as its legal basis if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
- Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
How to Exercise Your Rights: If you would like to exercise any of the rights described above, please contact us at this link: https://www.europe-samsung.com/gdpr/webform/uk. In your message, please indicate the right you would like to exercise and the information to which it relates.
Cross-border Transfer of Information. We maintain servers and systems in the United States hosted by third-party service providers. As a result, where the personal information that we collect through or in connection with the Platform and Tools is processed in the United States, we will take steps to ensure that the information receives the same level of protection as if it remained within the European Union. You may have a right to receive details of any safeguards that we have where your data is transferred outside the European Union, (e.g. to request a copy where the safeguard is documented, which may be redacted to ensure confidentiality). Retention. We will keep your information accurate, complete and up to date. We will retain your data for the period necessary to fulfill the different purposes outlined in section 2. Where we are required to do so to meet legal and regulatory requirements, we will retain your data for longer periods of time, but only where permitted to do so, including so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a possibility of legal action relating to your data or dealings.
10. CALIFORNIA PRIVACY RIGHTS
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of personally identifiable information to third parties for their direct marketing purposes in the preceding calendar year (e.g., requests made in 2018 will receive information about 2017 sharing activities). We comply with this law by giving users the ability to tell us not to share personally identifiable information with third parties for their direct marketing purposes. To make such a request, send an email to [email protected] We may need additional information to process your request.
11. CONTACT US (If you are the resident of a European country, you must follow the link in section 9.)
If you have questions about the privacy aspects of the Platform and Tools or would like to make a complaint, please contact us at [email protected].
12. CHANGES TO THIS POLICY
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Platform. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Platform.