Privacy Policy for EEA Residents

Last Updated:  July 2020

If you are located in the United States or any other country that is not a member of the European Economic Area (EEA), please visit our Privacy Policy for US and other non-EEA Residents instead.

1.) What This Privacy Policy Covers

AllClear ID, Inc., (“AllClear ID”) and its subsidiaries, (collectively, the “AllClear ID Group” or “we” or “us” or “our”) have created this EEA Privacy Policy ( the “Policy”) in relation to the processing of personal data of individuals located in the European Economic Area (“EEA Residents” or “you”) at the time of visiting the AllClear ID marketing website (www.allclearid.com, the “Website”), or otherwise interacting with the AllClear ID Group as a consumer, customer, or business partner (for example, through public events, direct marketing efforts, business relationships, or purchase of services). This Policy does not cover personal data gathered from current, former, or prospective employees of the AllClear ID Group in the course of their recruitment and/or employment.

This Policy outlines our commitment to protecting your privacy as an EEA Resident who visits the Website. If you are visiting the Website and this Policy does not apply to you, please refer instead to our Privacy Policy for non-EEA visitors at www.allclearid.com/privacy-policy

2.) Who is Responsible For Your Data

For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the “GDPR”), AllClear ID, Inc. (a Delaware corporation based in the state of Texas in the United States of America), is the controller responsible for any personal data we may gather about you when you visit the Website or otherwise interact with us as a consumer, customer, or business partner.

Encap AS, a subsidiary of AllClear ID, Inc., is our designated representative in the European Economic Area (“Designated Representative”). You can find contact details in the Contact Us section below.

We are not responsible for personal data that other parties may collect about you when you visit third-party websites via links from the Website.

3.)What Personal Data We Do and Don't Collect About You

No personal data from minors

The Website is not directed at children under the age of 16 ("minors"), and we do not knowingly collect personal data from minors. We encourage parents and legal guardians to monitor minors’ Internet usage and to help enforce this Policy by advising minors never to provide personal data through the Website. Likewise, we do not knowingly sell services or market to minors, or otherwise enter into business relationships with minors.

No sensitive personal data

We do not knowingly solicit or collect sensitive personal data or special categories of personal data (as described in Article 9 of the GDPR) from you. For the avoidance of doubt, such categories include personal data relating to health; genetics; race or ethnicity; political, religious, or philosophical beliefs; trade union membership; sexual history and sexual orientation; or criminal convictions. If we become aware that any such data has been provided to us, we will immediately take steps to delete it.

Personal data that we gather when you visit the Website

Logs

As with most other websites, when you visit the Website we collect certain information and store it in log files. This information includes:

  • internet protocol (IP) addresses
  • browser settings
  • browser type
  • the type of device you are using
  • the type of operating system you are using to access the Website
  • your activity on the Website
  • URLs of referring/exit pages
  • links you click on while visiting the Website
  • files you download from the Website
  • terms you enter into the Search boxes
  • date/time stamps

We do not connect any of your personal data gathered in our log files with cookies and similar technologies (see Cookies and Tracking Technologies below) or your physical location.

Account and Registration Information

When you visit the Website, we do not collect personal data about you from third parties that those third parties may already possess.

You are not required to create an account or to provide your name or contact information in order to browse the Website. However, where you do create an account, we collect personal data such as:

  • Your name
  • Your e-mail address
  • Your phone number
  • The name of the company you work for
  • Your title at the company you work for
  • The industry you work in

Data we generate internally about you

When storing your personal information, we may generate internal identifying numbers (“internal identifiers”) for the records associated with you, in order to manage our databases and systems efficiently and ensure that your personal data is associated with the correct set of records. These internal identifiers are not shared with other entities.

Other Submissions

When you submit web forms on the Website, or when you interact with the features on the Website, we may collect other personal data from you. These scenarios include participation in surveys, contests, promotions, sweepstakes, requesting customer support, or communicating with us via the Website. In such cases, we will make clear, at the time of collection, the specific additional personal data being collected and the purposes for which we are collecting it.

Personal data that we collect through other channels

If you provide personal data to us through channels outside of the Website (e.g., e-mail, telephone conversation, in person at a public event), we will make clear, at the time of collection, the specific additional personal data being collected and the purposes for which we are collecting it.

4.) How We Collect Personal Data About You

Cookies and Tracking Technologies

The Website uses cookies and similar technologies for a variety of purposes, mainly to provide you with a good user experience and to allow us to improve the Website in the future. Some of the cookies the Website uses are necessary for certain features of the site to function, such as setting your privacy preferences or filling in forms. If you set your browser to block these Strictly Necessary Cookies, these features of the Website will not work.

We use other cookies to track the performance of the Website, so that we can deliver relevant content to our users and improve the Website’s performance (“Performance Cookies”). These cookies allow us to count visits and traffic sources, and to see how visitors move around the Website.

Where you consent to Performance Cookies, personal data that we collect about your visit is processed by Google Analytics. All information we receive from Google Analytics about data collected via these cookies is aggregated, and thus anonymized. Google Analytics may be able to associate information that these performance cookies gather about your visit to the Website with information about your visits to other websites using the same device and browser. If you wish to opt out of Google Analytics cookies entirely, you can do so using Google Analytics’ opt-out tool at https://tools.google.com/dlpage/gaoptout/.

Performance Cookies are not essential to the functioning of the Website, and all features of the Website will continue to work if you choose to opt out of them.

We also use a technology commonly known as “web beacons”, or “pixel tags”, for performance analytics, such as counting the number of visitors to a web page or measuring the effectiveness of an advertising campaign. A web beacon is an electronic image, often a single pixel that is ordinarily not visible to website visitors. The web beacon may be associated with a performance-tracking cookie placed on your computer when you visit the Website. When your browser downloads the web beacon, the server hosting the Website logs details like your IP address, the date/time stamp, and information about any associated Performance Cookies.

The Website also contains content provided via third parties, such as videos hosted by YouTube. These third parties may set cookies which they use to build a profile of your interests and show you relevant advertisements on other sites (“Targeting Cookies”). If you have a relationship (such as an account) with a third party, that third party may be able to associate your identity with its content displayed on the Website. We have no control over the cookies set by such third parties. If you block these third-party cookies on the Website, certain features of the content on the Website provided via these third-party services may not work.

The Website does not respond to “do not track” signals from browsers. Thus, your selection of the “do not track” option provided by your browser may not prevent our collection of cookie information.

The following button will take you to our cookie preference center, where you can obtain additional information on the different types of cookies used by the Site, as well as edit and save your preferences for their use:

Cookie Settings

When you opt in to providing personal data to us via the Website

On some pages of the Website, we may ask if you wish to provide us with personal data, such as your name, employer, and contact details, so that we may contact you for direct marketing purposes. For example, if you click on a link to download a white paper, we may ask for your name and email address so that we can email you information about related services AllClear ID or its business partners may offer. You may decline to provide personal data for such direct marketing purposes without affecting your ability to use the features of the Website. Likewise, you may opt to provide us with personal data for direct marketing purposes through other means, such as providing your contact details to an AllClear ID representative for this purpose at a public event.

If you do opt to provide personal data for direct marketing purposes, you may subsequently opt out at any time by contacting us using the details in the Contact Us section below, or by following the unsubscribe instructions included in our marketing communications.

You may also provide personal data to us in the course of a business relationship, either as a customer or as a business partner, so that we may fulfill our contractual obligations and pursue our legitimate interests pertaining to the business relationship. Personal data collected for these purposes will not be used for direct marketing purposes without your explicit consent.

5.) How We Use The Personal Data That We Collect

Personal data automatically collected from Website visits

We may use the information that we automatically collect about you during your visits to the Website (including personal data) for a variety of purposes, including:

  • Security and availability. We use information about visits to the Website to monitor for, interrupt, and prevent suspicious activity, such as denial-of-service attacks or attempts to gain unauthorised access to our systems.
  • To improve the Website, increase Website visitor engagement, and market our products and services. We use aggregated information about Website visitors and their activities while on the Website to improve the Website’s functionality and performance, to make it easier to use, and to deliver a more compelling user experience that provides the Website visitors with relevant and timely information. Aggregated data about Website visitors may also be used in our decisions regarding marketing (for example, the location and preferred device types of the Website’s visitors may be taken into account when we design and purchase advertising). You can opt-out of receiving marketing communications at any time by contacting us using the details in the Contact Us section below, or by following the unsubscribe instructions included in our marketing communications
  • To customize your user experience. We use information stored using cookies to personalize your experience on the Website and ensure that the information presented is relevant to you.

Personal data you provide to us

The personal data that you provide to us may be used for the following purposes:

  • To verify your e-mail address.
  • To fulfill any requests that you make.
  • To provide information about our products and services, including promotional materials, to you or the company you work for, using the contact information you provided to us.
  • To inform you about changes to our policies.
  • To send informational e-mail on topics of professional interest, such as security and privacy.
  • To contact you in the event of a data breach.

See the Your Data Protection Rights section below for information on how to opt out of marketing communications from us at any time.

6.) Lawful Basis For Processing

Our lawful basis for collecting and using the personal data of EEA Residents will depend on the personal data concerned and the specific context in which we collect it.

However, we will normally collect personal data from you only:

  • where we need the personal data to fulfill a request from you;
  • where we have your consent to do so; or
  • where the processing is in our legitimate interests and not overridden by your rights.

In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person (e.g., exercising your rights under data protection law and making rights’ requests per Section Your data protection rights below or the establishment and defense of legal claims and rights).

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).

If we collect and use your personal data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are. Where we collect your personal data for direct marketing purposes, we will make clear at the time of collection that we wish to use the personal data for direct marketing purposes, and will seek your explicit consent to do so. Withholding or withdrawing your consent for us to use your personal data for direct marketing purposes will not affect any other business relationship you may have with the AllClear ID Group, your ability to use the Website, or our processing as appropriate (for non-direct marketing activities) of any of your personal data collected for other purposes.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, you may contact us using the details in the Contact Us section below.

7.) How We Share Your Information

Third Party Service Providers

We also work with third-party service providers who provide website hosting, virtual infrastructure, analysis and other services for us, which may require them to access or use information and personal data we have collected about you. If a service provider needs to access your personal data to perform services on our behalf, they do so under contractual obligations which protect your personal data in accordance with our policies and applicable laws.

We also use the services of third parties to process data that we collect about you when you visit the Website. These other companies are data processors, and we have agreements in place with them to ensure that they process your data according to the standards of this Policy and applicable law.

We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

Sharing information when required by government authorities and regulators
We may share information about you with a third party such as government authorities and regulators if we believe that sharing is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, or to protect the security of our products and services or to protect personal data that we control.

AllClear ID Group Sharing
We may share your personal data with our Designated Representative so that they can assist you when you contact us with requests regarding your personal data. We may also share your personal data with any members of the AllClear ID Group, and they may only use that personal data for purposes already described in this Policy.

With your consent
We share your personal data with third parties where we have your consent to do so.

8.) How We Store Your Information And Keep It Safe

We will retain your personal data for as long as is reasonably necessary to fulfill the relevant purposes set out in this Policy. We are committed to taking all reasonable measures to keep your personal data private, accurate, and secure, to use and share your personal data only for approved purposes as explained in this Policy, and to delete your personal data once it is no longer needed. We implement information security best practices for the development, maintenance, and use of software and systems that we manage, including measures to protect against both unauthorized and accidental access, disclosure, or alteration. Where we use the services of third parties to store your information, we perform due diligence on those third parties to ensure that they meet acceptable standards of security and confidentiality, and we have contracts in place with those third parties which obligate them to treat your personal data according to the standards that this Policy and applicable laws require. We keep your personal data only for as long as necessary to accomplish the purposes for which it was collected, and we have processes to identify personal data that is no longer needed, and to permanently delete it in a timely manner. We also conduct reviews of what personal data we collect to ensure that we are not collecting personal data which is not needed for the purposes explained in this Policy.

9.) Your Data Protection Rights

You have the following data protection rights:

  • You have the right to access, correct, update, or request deletion of your personal information. Please keep us informed if your personal data changes during your relationship with us.
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information, or request portability of your personal information.
  • You have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt out” link in the marketing e-mails we send you, or by contacting us using the details in the Contact Us section below.
  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

Please contact our Designated Representative regarding the exercise of your rights using the details in the Contact Us section below. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

10.) How We Transfer Personal Information Internationally

We do not share your personal data with third parties, unless it is necessary to carry out your request, for our professional or legitimate business needs, or as required or permitted by law. Where we do transfer your personal data to third parties or service providers, appropriate arrangements will be made in order to ensure correct and secure data processing in compliance with applicable data protection law.

We store personal data about visitors to the Website, and other individuals who have a business relationship with AllClear ID Group, in the United States of America. We have implemented safeguards to ensure an adequate level of data protection where your personal data is transferred to countries outside the EEA.

You can obtain further details regarding the protection given to your personal data when it is transferred outside the EEA by contacting us using the details in the Contact Us section below.

11.) Updates To This Policy

We may change this Privacy Policy and, when we do, will post the Last Updated date so that you will always be aware of what information we collect, use, and disclose.

We encourage you to review this Privacy Policy from time to time. If, after reviewing this policy, you have any questions or concerns, please contact us.

12.) Contact Us

If you have enquiries or requests regarding your privacy and personal data, please contact our Designated Representative using the contact details below:

AllClear ID’s European Representative
Email: privacy.eea@allclearid.com
Mail: Encap AS
Attention: Privacy Officer
Stortingsgata 4
0158 Oslo
NORWAY