Website Privacy Notice
Something Digital and our affiliated companies worldwide (“Something Digital”) are a global professional services firm focused on delivering digital transformation for our clients. Something Digital respects you and we are committed to honoring and protecting your privacy. The reason we collect your personal data is to improve our services to you. This Website Privacy Notice describes our approach to privacy and our practices regarding why we collect your personal data, what data we are collecting, how we process it and how you can manage and delete your personal data. If you have any questions or concerns about this Website Privacy Notice or your personal data, please contact us at firstname.lastname@example.org.
Where we determine the purpose and means of processing personal data, Something Digital will be a controller. Where we act as a processor in our capacity of providing services to a customer, we will only process personal data in accordance with the instructions of the customer. The customer will be the data controller of that personal data and will be responsible to data subjects for the way in which their personal data is processed. Where applicable, in accordance with data protection laws we shall assist the data controller in effecting data subject rights.
What Personal Data We Collect and How We Collect It
Something Digital, may at times collect your personal data in one of the following ways:
- By entering information such as your name, and email address, country of residence, company you represent, industry and details of an inquiry on our Contact page as well as other forms throughout our website, you enable us to respond to a general/ business inquiry made by you or on behalf of the company that you represent. If you wish to be contacted by telephone, we may also collect your phone number.
- E-mail Communications: If you are a recipient of our marketing communications, we may track whenever you receive, open, click a link, or share an e-mail you receive from Something Digital. Please visit our customer privacy notice for further details. To unsubscribe from Something Digital marketing communications, please visit our subscription center.
- Information from Other Sources: Something Digital might receive information about you from other sources, such as public sources, social media, directories, registries to ensure the accuracy and completeness of your personal data.
Purpose and Lawful Basis For Processing Personal Data
- With your consent. Where we require your consent you will find opt-in mechanisms and you have the ability to withdraw consent at all times.
- Where we need to perform the contract we are about to enter into or have entered into with you. For example, when we perform our services to you.
- Where we need to comply with a legal or regulatory obligation. This will include maintaining records, compliance checks or screening and recording (e.g. anti-money laundering, financial and credit checks, fraud and crime prevention and detection, trade sanctions and embargo laws). This may include automated checks of personal data you provide about your identity against relevant databases and contacting you to confirm your identity or making records of our communications with you for compliance purposes.
- Where it is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests. Our legitimate interest will include for example, market research purposes, marketing purposes and appropriate controls to ensure our website, processes and procedures are running effectively for the prevention and detention of against fraud and for IT security purposes. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
If processing of personal data is subject to any other laws, then the lawful basis of processing personal data may be different to that set out above and in those circumstances will be based on national laws.
Something Digital shall only process the received information pursuant to pursue our legitimate business interests for example screening CVs of prospective candidates, establishing communication with prospective customers (whom you represent) and personnel with general/ business inquiries and to enhance our user experience. Please visit https://www.somethingdigital.com/customer-privacy-notice to see our customer privacy notice.
You also have the option to subscribe/opt-in to receive newsletters, thought leadership content and/or marketing collateral. You can always opt-out of such options using our subscription center or write to email@example.com. Something Digital shall adhere to your preferences.
Something Digital implements industry standard security measures to keep your personal data secure and confidential, including but not limited to:
- Restriction of access to your personal data to Something Digital employees strictly on a need to know basis, such as responding to an inquiry or request.
- Implementation of physical, electronic, administrative, technical and procedural safeguards that comply with all applicable rules, laws, legislation and regulations to protect your personal data from unauthorized or inappropriate access, alteration, disclosure and/or destruction. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when you are done using a shared computer.
- Something Digital employees who misuse personal data are subject to strict disciplinary action, as it is a violation of the Integrity Policy of Something Digital.
Who We May Share Your Personal Data With
- The personal data Something Digital collects from you is stored in one or more databases hosted by third parties. These third parties do not use or have access to your personal data for any purpose other than cloud storage and retrieval.
- Something Digital shares information between our group companies for business and administrative purposes. • Where required or permitted by law, information may be provided to others, such as but not limited to regulators, under legal process, enforceable government directives.
International and Group Company Transfers of Personal Data
We are part of an international group of companies and, as such, transfer personal data concerning you to countries outside the European Union (EU). Please visit https://www.genpact.com/about-us/regions to see a list of the locations within our corporate group.
We transfer personal data between our group companies and data centers for the purposes described above. We may also transfer personal data to our third party suppliers outside of the EU as described above.
Your personal data may be stored in databases located outside of the EU including in India. The database is controlled by our administrative staff located outside of the EU including in India and can be accessed electronically.
Where we transfer personal data outside of EU, we either transfer personal data to countries that provide an adequate level of protection as determined by the European Commission or we have appropriate safeguards in place. Appropriate safeguards to cover these transfers are in the form of standard contractual/data protection clauses adopted by the European Commission. Please visit http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:EN:PDF to know more about standard contractual/data protection clauses.
Where we transfer personal data between our group companies we have covered these transfers by entering into standard contractual clauses adopted by the European Commission. If you would like more information on the any of the data transfer mechanisms on which we rely please contact our Data Protection Officer, details available in the contact section below.
Data Storage and Retention
Something Digital shall retain your personal data pursuant to the business purposes. We will only keep your personal data for as long as is reasonably necessary taking into consideration our purposes outlined above or to comply with legal, accounting or reporting requirements under applicable law(s).
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Personal data received from prospective customers shall be retained for the duration of the prospective customer’s business relationship with the Something Digital and in accordance with the retention criteria set out in our customer privacy notice. Please visit https://www.somethingdigital.com/customer-privacy-notice to see our customer privacy notice for further details.
For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at firstname.lastname@example.org.
Existence of Automated Profiling
Something Digital uses automated profiling in limited circumstances relating to email campaigns. As part of our email campaigns, we may track when you receive, open, click a link, or share an e-mail you receive from Something Digital using a Something Digital managed automated solution. The automated solution profiles the information tracked to evaluate your interest in Something Digital’s service offerings and/or promotions. This enables us to identify and target potential customers and/or business partners and aims to provide you with relevant and timely content based on your indicated interests.
Data Subject Rights
You may have certain rights relating to your personal data provided under the GDPR. These include the right to:
- Request access to your personal data and request details of the processing activities conducted by Something Digital.
- Request that your personal data is rectified if it is inaccurate or incomplete
- Request erasure of your personal data in certain circumstances.
- Request restriction of the processing of your personal data in certain circumstances.
- Object to the processing of your personal data in certain circumstances.
- Receive your personal data provided to us as a controller in a structured, commonly used and machine-readable format in certain circumstances.
- Object to, and not to be subject to a decision based solely on, automated processing (including profiling), which produces legal effects or significantly affects you.
- Withdraw your consent provided at any time by contacting us.
To exercise the rights outlined above in respect of your personal data you may write to us at email@example.com.
If you are a California resident, you may have certain rights relating to your personal data provided under the California Consumer Privacy Act (CCPA):
- The right to know what information Something Digital collects and discloses.
- The right to access what personal information has been collected about you by making a proper Verifiable Consumer Request (VCR). Through a VCR, you may request:
- The categories of personal information collected about you in the preceding 12 months;
- The categories of sources from which personal information is collected; the business purpose for collecting personal information;
- The categories of third parties with who Something Digital shares personal information; and
- Specific pieces of personal information collected about you.
- The right to request deletion of personal information that has been collected about you, subject to certain exceptions.
- The right to request that your personal information be transferred to a third party.
- The right to non-discrimination against you for exercising any of the rights listed above.
Something Digital does not sell personal information as defined in section 1798.140(t) of the CCPA. Something Digital also does not sell the personal information of children under age 16 without affirmative authorization.
Something Digital will respond to a VCR within 45 days. Should we require more time, Something Digital will notify you of the extension period and the reason for the extension in writing. To the extend possible, we will provide you with your personal information in a format that you can share with other businesses.
To exercise your rights with respect to your personal information, you may submit a Verifiable Consumer Request by emailing firstname.lastname@example.org or calling 1(888) 914-9661 and entering in the following ID: 112797.
Residents of Canada have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA) or if applicable, certain provincial laws:
- The right to know why your personal information will be collected, used, and/or disclosed.
- The right to withdraw consent (where consent was required) to the collection, use, disclosure of your personal information at any time, subject to legal and contractual restrictions and reasonable notice.
- The right to require that your personal information is accurate, complete, and up-to-date. If the information is inaccurate, incomplete, and/or out-of-date, you have the right to request that it is corrected.
- The right to request access to your personal information, subject to exceptions set out in applicable privacy legislation.
- The right to address a challenge concerning compliance with the above rights to the designated individual accountable for Something Digital’s compliance.
If you have any questions or concerns as to how your data is being processed, you can contact us by writing to email@example.com.
In the first instance, please contact us with concerns you may have. Data protection laws such as the GDPR gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws has occurred.
Changes to our Website Privacy Notice
This Website Privacy Notice was last updated in May 2021 and Something Digital will notify you of changes we may make to this privacy notice where required, however we would recommend that you look back at this notice from time to time to check for any updates.