Effective Date: 10/19/2015
U.S—E.U and U.S—Swiss Safe Harbor
Determine, Inc. complies with the U.S. – E.U. Safe Harbor framework and the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Determine, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Determine, Inc. certification, please visit http://www.export.gov/safeharbor/
Collection of your Personal Information
Determine, Inc. collects personally identifiable information, such as your e-mail address, name, home or work address or telephone number and company information such as business address and employee count.
There is also information about your computer hardware and software that is automatically collected by Determine, Inc. on our website. This information can include: your IP address, browser type, domain names, access times and referring Web site addresses. This information, which does not identify individual users, is used by Determine, Inc. for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Determine, Inc. Web site. We do not link this automatically-collected data to personally identifiable information.
Data Collected through the Determine, Inc. CPQ and CLM Services
Determine, Inc collects and processes 3rd party personally identifiable information under the direction of our Clients. We have no ownership of this information or any direct relationship with individuals whose personally identifiable information may be processed as part of providing our Service.
An individual who seeks access to their data, seeks to correct, amend or delete inaccurate data or wishes to opt-out of communications from a Determine, Inc Client should direct his/her query to the Determine, Inc Client he/she interacts with directly (the data controller). If a Determine, Inc Client requests that we remove personally identifiable information on their behalf, we will respond to their request within 30 days.
Determine, Inc may transfer personal information to other companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
Determine, Inc will retain personal data we process on behalf of our Clients for as long as needed to provide services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Clients who use the services offered on our Site may submit the personal information of other individuals at their organization to register them as authorized users. It is the Clients obligation, as the data controller, to inform its authorized users about the purposes for which information about them is collected and may be used on this Service. Authorized users can update or remove their account information at any time by logging into the Site and editing their account information, or by contacting their administrator.
Use of your Personal Information
Determine, Inc. collects and uses your personal information to operate the Determine, Inc. Web site and deliver the services you have requested. Determine, Inc. also uses your personally identifiable information to inform you of other products or services available from Determine, Inc. and its affiliates. Determine, Inc. may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
Determine, Inc. keeps track of the Web sites and pages our customers visit within Determine, Inc., in order to determine what Determine, Inc. services are the most popular. This data is used to deliver customized content and advertising within Determine, Inc. to customers whose behavior indicates that they are interested in a particular subject area.
In addition, Determine, Inc. may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Determine, Inc., and they are required to maintain the confidentiality of your information.
Determine, Inc. Web sites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process, such as a subpoena, served on Determine, Inc. or the site; (b) protect and defend the rights or property of Determine, Inc.; and, (c) act under exigent circumstances to protect the personal safety of users of Determine, Inc., or the public.
If Determine, Inc. is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
What is a “cookie”?
A “cookie” is a tracking technology that designates a text file that may be recorded when visiting a website in a dedicated area of your computer, smartphone, or other computer media.
Subject to your choices, cookies are used by the visited website to send information to your browser and to allow this browser to return information to the website visited for tracking purposes.
Cookies allow the issuer to store information about your browsing preferences during the period of validity or registration of the cookie.
How long cookies are kept?
The retention period for cookie information may not, in any event, exceed thirteen (13) months, unless otherwise agreed by you. Cookies will be permanently deleted following this time period.
Determine uses several categories of cookies, each of them fulfilling different functions:
- Cookies required for technical purposes
- Audience measurement cookies
- Cookies for uploading content from social platforms and sharing
The 3 different categories of cookies that can be used on the DETERMINE website are described below.
- Cookies required for technical purposes – These cookies are necessary for the proper functioning of our Website.
- Audience measurement cookies – These cookies are intended to establish the volume and establish statistics of attendance of our sites, the various headings as well as the use of services offered on each of them.
- Cookies for uploading content from social platforms sharing – These cookies are used to publish/share social media content
The information that Determine collects through cookies is only used for its own purposes. This information is not the subject of a communication outside the Determine group.
How to manage cookies?
- Prior consent to the deposit of cookies – It is considered that you have given your consent to the deposit of cookies for this website, provided that:
- You have accepted our cookies policy by clicking on the information banner on the homepage of our website.
- You continued browsing the Determine website or clicked on an element of the website (image, link, button “search”).
- You have set your internet browser to consent to the processing of cookies.
Your agreement is only valid for a period of thirteen (13) months from the first deposit of cookies in your terminal equipment. Once this period has passed, your agreement will be requested again for the use of these cookies.
By refusing this consent, you will still be able to access the public parts of the website, but some functions may be limited.
- Change cookie settings – By default, most internet browsers are set to automatically accept cookies. It is possible at any time to change the settings applicable to cookies by changing the browser settings of your internet browser. The configuration of each browser is different, we suggest you to consult the Help section of your browser that will know how to change your wishes for cookies.
- For Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
- For Safari: https://help.apple.com/safari/mac/9.0/#/sfri11471
- For Chrome: https://support.google.com/chrome/answer/95647
- For Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- For Opera: https://www.opera.com/help/tutorials/security/privacy/
- For other browsers: Please refer to the help of your browser or go to the publisher’s website.
- For more information – For more information on cookies, we recommend you visit the CNIL website at the following address: https://www.cnil.fr/en/home
The Determine, Inc. Web site (“Site”) uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Determine, Inc. pages, or register with Determine, Inc. site or services, a cookie helps Determine, Inc. to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Determine, Inc. Web site, the information you previously provided can be retrieved, so you can easily use the Determine, Inc. features that you customized.
Third Party Cookies. We may also engage third parties to track and analyze Site data. We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyze Site usage. Such third parties may combine the information that we provide about you with other information that they have collected. This Policy does not cover such third parties’ use of the data they collect. We may also allow third parties, such as Google, to place cookies on our Site, in order to display targeted advertisements on other websites. For more information, see the “Third-Party Ad Networks” below.
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 disable and manage your cookies settings. If you disable cookies you may still browse public areas of the Site, but some features and Services 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 web pages. We and our third party service providers may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site, to among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs and/or personalized tagged links in e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and identify when recipients click on the links in our emails.
Site Analytics. As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. We do not link this automatically-collected data to personally identifiable information.
You may opt-out of many third-party ad networks. The website, http://www.networkadvertising.org/optout_nonppii.asp, provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including how to “opt-out” of third-party ad networks operated by NAI members. You also may visit the Digital Advertising Alliance (DAA) at http://www.aboutads.info/choices/ for information about opting out of targeted advertising and your choices regarding having information used by DAA member companies, including how to “opt-out” of third-party ad networks operated by DAA members. Opting out of one or more NAI members or DAA member (many of which will be the same) ad networks only means that those members will no longer deliver targeted content or ads to you, but it does not mean you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, or use a different computer or change web browsers, your NAI or DAA opt-out may no longer, be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.
Security of your Personal Information
The security of personal information is important to us. Determine, Inc. secures your personal information from unauthorized access, use or disclosure. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. When sensitive information (such as log-in credentials) is submitted, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at firstname.lastname@example.org.
Access and Choice
If your personal information changes, you may correct, update, amend, remove, or ask to have it removed by making the change on your user account settings page, by contacting your dedicated Account Representative, or by contacting us by telephone or postal mail at the contact information listed below. If you no longer desire our Services, please contact your Account Representative directly. We will respond to your request within 30 days. We will retain your information for as long as your account is active, as needed to provide you services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We may occasionally send you promotional material on behalf of business partners, with your consent. You may also sign up for periodic newsletter and/or blog updates from our Web site. In both of these cases, we will use your name and email address to send these materials to you. Out of respect for your privacy, you may choose to stop receiving these communications by following the unsubscribe instructions included in these emails or you can contact us at email@example.com.
We may also provide you the opportunity to participate in contests or surveys via email. If you participate, we may request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address).
Third Party Links and Plug-ins
Our Site includes links to other Web sites whose privacy practices may differ from those of Determine, Inc. If you submit personal information to any of those sites, your information is governed by their privacy policies.Determine, Inc. is not responsible for the privacy statements or other content on Web sites outside of the Determine, Inc. and Determine, Inc. family of Web sites.
Changes to this Statement
Determine, Inc. welcomes your comments regarding this Statement of Privacy. If you believe that Determine, Inc. has not adhered to this Statement, please contact Determine, Inc. at firstname.lastname@example.org. Or you can reach us by telephone or mail at:
2121 S. El Camino Real
We will use commercially reasonable efforts to promptly determine and remedy the problem