This page tells you everything you need to know about how ShadApps protects your personal data and what your rights are in relation to your personal data:
You will also find further information on this page about:
- Your Website Data
- Your Cookie Data (and other tracking technologies)
- Your Marketing Data
- Your Online Recruitment Data
If you have any questions concerning data privacy or you want to let us know about website/marketing permissions, please see how to contact us below.
Any changes we may make in the future to “How ShadApps protects your personal data” or the statements you see here will be posted on this page.
This privacy statement is effective July 19th, 2017
How ShadApps protects your personal data
What personal data do we collect?
We collect personal data of our workers, candidates, suppliers, business contacts and website users.
We will always try to give individuals appropriate notice of what data will be collected and how it will be used. Whatever happens, we will only process that data if we consider it fair and lawful to do so.
Will we share your personal data with outside parties?
We will not sell personal data to third parties. We may transfer personal data to our contracted service providers and advisors who may be located in other countries. Before we do so, we take steps to ensure that your personal data will be given adequate protection as required by relevant data protection laws and ShadApps’ internal policies.
However, there will be other times when we need to share or disclose personal data you provide for a specific purpose, for example:
- In the case of an event where we need to provide our caterer with meal preference information or we are running a joint event and have informed you that the data will be shared with our partners. But again, we will notify you as to why we are asking for specific information and it is completely up to you whether you want to provide it;
- We may need to disclose your personal data to third parties in the event that we sell or liquidate any part of our business or assets;
What about sensitive personal data?
What about data security?
We take appropriate steps to maintain the security of personal data collected. Regarding your use of our websites you should understand that the open nature of the Internet is such that information and personal data may flow over networks connecting you to our systems without security measures and may be accessed and used by people other than those for whom the data is intended.
Our site may, from time to time, contain links to and from the sites of our partner networks, advertisers and affiliates. If you follow a link to any of these sites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for these policies or sites. Please check these policies before you submit any personal data to these sites.
Retention of your data
We will retain your personal data only for as long as is necessary. If you have an account with us, we will only keep the data whilst your account is active or for as long as needed to provide services to you and, as further needed for us to comply with our global legal and contractual obligations.
You are entitled to know whether we hold personal data about you and, if we do, to have access to that personal data and require it to be corrected if it is inaccurate. We generally do not make decisions by purely automatic means, but if we do, you have the right to object.
You have a question or complaint
If you can’t find what you’re looking for here, or have a concern about our use of your personal data, please contact us.
Your privacy on ShadApps’ website
The primary purpose of ShadApps’ website is to be a dynamic resource and business tool to help you learn more about ShadApps. We want you to feel secure when visiting our website and are committed to maintaining your privacy when doing so.
What information do we gather?
ShadApps collects information at its websites in two ways: (1) directly (for example, when you provide information to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website’s technology).
We may collect and process the following information:
- Information that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts, registering for a conference or requesting a white paper or further information. Pages that collect this type of information may provide further information as to why your data is needed and how it will be used. It is completely up to you whether you want to provide it.
- If you contact us, we may keep a record of that correspondence.
- We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Any postings, comments or other content that you upload or post to an ShadApps website.
- Our website collects information about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
- Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the Cookiessection below for more information.
When this information relates to or identifies you, we will treat it as “personal data.”
How do we use information that we collect from the site?
We use personal data to provide you with information you request, process online job applications, and for other purposes which we would describe to you at the point where it is collected or which will be obvious to you. For example:
- To fulfill your requests for white papers, articles, newsletters or other content.
- For surveys or research questionnaires.
- To personalize your experience at our website.
- To contact you for marketing purposes where you have agreed to this.
We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. Please see the Cookies section below for more information.
What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu.
Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that the advertisements and other content you see online are more relevant to you and your interests. They can be set by the website that you are visiting (known as first party cookies) or by another entity such as an advertising network (known as third party cookies).The cookies used on this website have been categorized on the basis of the four categories found in the ICC UK Cookie guide. A list of all the cookies used on this website by category is set out below. Within the four categories, cookies can either be session or persistent. Session cookies are temporary and once you close the browser window they are deleted from your device. Persistent cookies remain on your device for a longer period and are used by the website to recognize your device when you return.
What other tracking technology do we use?
We may also use web beacons (including conversion pixels) or other technologies for similar purposes and we may include these on our sites, in marketing e-mail messages or our newsletters to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but may work in conjunction with cookies to monitor website activity and the information on cookies below also applies to web beacons and similar technologies. Conversion pixels are small codes located on a particular web page which are triggered when someone visits a page resulting in an increase in the conversion count.
What if I don’t want cookies?
By using our website you agree that we can place cookies and other similar technologies on your device as explained below. If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this. For more information on managing cookies see www.allaboutcookies.org/manage-cookies. Current “Do Not Track” initiatives are not recognized by our website.
Please bear in mind that deleting and blocking cookies will have an impact on your user experience as parts of the website may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our website or click a link in a targeted email we have sent you, even if you have previously deleted our cookies.
You cannot remove or block web beacons or personalized URLs, as they form part of the content of web pages and emails rather than placing information on your device. But, as they work in conjunction with cookies, turning off cookies will also prevent any web beacons from tracking your user activity on our site. The web beacon will still account for an anonymous visit, but your unique information will not be recorded.
What types of cookies are there and which ones does this website use?
- Strictly necessary cookies – These cookies are essential to enable you to move around the site and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for cannot be provided.
- Performance cookies – These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how a website works.
We categorize the following as performance cookies:
– Referrer URL (internal page) – Used to store the URL of the previous page visited. Allows us to track how visitors navigate through our website.
– Referrer URL (external page, including if you click on links on ShadApps social media pages). Used to store the URL which refers a visitor to our website so we may understand what URLs are referring visitors to our website.
– URL history – Used to store the page visited by a user before that user submits a form. Also, used to display recently viewed articles to each visitor.
- Unregistered Visitor Cookie – A unique identifier given to each visitor to allow analysis on how unregistered visitors use our website.
- Session management cookies – These cookies allow us to follow the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close their browser window.Our session management cookies are created temporarily. Once you close your browser, our session management cookies are deleted.
- Functionality cookies – These cookies allow a website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local information or news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. These cookies cannot track your browsing activity on other websites. They don’t gather any information about you that could be used for advertising or remembering where you’ve been on the internet outside our website. We categorize the following as functionality cookies:
– Recently viewed pages – Stores pages visited by the user on our website and displays them in right hand navigation for easy reference.
– Search history – Stores searches on our website conducted by the user and displays them for the user in the right hand navigation for easy reference.
- Targeting cookies – These cookies are used to: (1) deliver advertisements that are targeted to be relevant to you, (2) limit the number of times you see an advertisement, (3) help measure the effectiveness of the advertising campaign, and (4) understand people’s behavior after they view an ad. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often they will be linked to website functionality provided by the other organization. ShadApps website does not contain any third party advertising but these cookies may be used on third party websites and third parties may use them on our website as follows:
– If you click on an ShadApps advertisement on a non-ShadApps website, a cookie may be used to log which website you are on, to ensure our advertisements are served effectively and to measure whether our advertisements are viewed. ShadApps may use service providers such as Doubleclick, MediaMind, www.DidIt.it and others for these purposes.
– We also partner with certain social media websites such as Facebook and Twitter to add conversion pixels to certain pages on our website that allow us to re-engage website visitors. A conversion pixel is a small code located on a particular web page which is triggered when someone visits a page resulting in an increase in the conversion count. These pixels enable us to advertise to those website visitors within Facebook and Twitter and continue their experience with ShadApps.
Some of the cookies we use don’t collect information that identifies a visitor. For example –
– Performance cookies (see above)
– Targeting cookies (see above) where you are not a registered user
In other cases, we can associate cookie information (including information from cookies placed via our advertisements on third party sites) with an identifiable individual. For example–
– If a user is a registered user (see RegisteredVisitorCookie above)
– If we send you a targeted email which includes web beacons, cookies or similar technologies we will know whether you open, read, or delete the message.
– When you click a link in a marketing e-mail you receive from ShadApps, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
- Non-cookie tracking technologies – ShadApps also employs technologies that perform similar functions to cookies, but that may not respond to browser settings intended for use with cookies. These include personalized URLs (PURLs), web beacons, and other similar technologies.
The following describes our use of personal data for marketing purposes:
- Sources of marketing data
- Targeted E-mail
- Customer Relationship Management(CRM) Databases
- Use of ShadApps Websites
- Combining and Analyzing Personal Data
Sources of Marketing Data.
The bulk of the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company.
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from ShadApps, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
Targeted e-mails from ShadApps may include additional data privacy information, as required by applicable laws.
Combining and Analyzing Personal Data
As described above, we may combine data from publicly available sources, and from our e-mail, website, and personal interactions with you. We combine this data to better understand your needs and the needs of your company, to assess the suitability of our service offerings for your needs, and to perform the other activities described throughout this privacy statement.
Data privacy query/rights/complaints
Please contact us if:
- You have a general question about how ShadApps protects your personal data privacy
- You wish to make a complaint about ShadApps use of your data
- You would like to discontinue marketing communications to you
- You have a more general question about ShadApps.
GDPR COMPLIANCE STATEMENT
The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
Shadapps are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR.
We are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We are Preparing for the GDPR
We already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018 . Our preparation includes:
• Policies & Procedures – revising data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –
• Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
• Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
• Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
• International Data Transfers & Third-Party Disclosures – where we stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
• Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
• Legal Basis for Processing – we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
• Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
• Obtaining Consent – we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via website, of an individual’s right to access any personal information that Shadapps processes about them and to request information about: –
• What personal data we hold about them
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from them, information about the source
• The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
• The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
• The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organisational Measures
Shadapps takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures.
Shadapps understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.