Privacy Policy

*This privacy statement is effective as of June 1, 2018. Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.*

We believe in utmost clarity and transparency in customer relations. Here is everything you need to know about how FaceorbitTM protects the personal data we process and control, with respect to your data and the rights you have in relation to such processing.

We understand the degree of import an investment is to you. Thus, to offer you clarity about the highlights of FaceorbitTM as a surveillance partner in your lives. Below is a generalisation of data processing and elaboration on specific facets of the application to aid you make a consciously aware decision.

FaceorbitTM attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure when you deal with FaceorbitTM, to be assured that your personal data is in good hands.

FaceorbitTM protects your personal data in accordance with applicable laws and our data privacy policies. In addition, FaceorbitTM maintains the appropriate technical and organizational measures to protect such data against any unauthorized or unlawful processing and/or accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of, or damage thereto.

Which categories of personal data do we collect and how do we process such personal data? next

We collect personal data of our employees, potential employees, clients, suppliers, business contacts, shareholders and website users. In case the data collected is not listed in the privacy statement, concerned individual(s)/enterprise is lawfully notified of the nature of data collected and their use by FaceorbitTM.

The personal data collected by us is put into specific categories to provide you with easy accessibility, which is broadly elaborated in the successive sections (How do we use personal data when you visit FaceorbitTM’s website?, How do we use cookies and other tracking technologies?, How do we use personal data when you visit our offices? and How do we use personal data for marketing purposes?) as well as any other categories of data referred to in this privacy statement or in other statements you have received.

Except for certain information as mandated by law, your decision to provide any personal data to us is voluntary. You will, therefore, not be subject to any adverse consequences such non-compliance to provide data. However, if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement, and accessibility to tools and functions operative on the basis of such data would be restricted.

If you provide us with personal data of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that he/she has given consent for sharing such information with FaceorbitTM.

The aforementioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly, from certain third parties (for example, through our website’s technology). The third parties include our affiliates, public authorities, public websites and social media, suppliers and vendors.

For what purpose and on what legal basis do we use your personal data? next

FaceorbitTM uses your personal data only on the event of purposive requirement of such information. Please click here for:

  • A list of the purposes for which FaceorbitTM uses your personal data and
  • An overview of the legal basis for each purpose.

While the table clearly states that we rely upon legitimate interests for a given purpose, we are of the opinion that our interests should not override your interests, rights or freedoms, given:

  • The transparency we provide on the processing activity,
  • Our privacy by design approach, (iii) our regular privacy reviews, and (iv) the rights you have in relation to the processing activity. Kindly contact us if you wish to obtain further information on the balancing test approach.

We process your personal data for the purposes mentioned above, based on your prior consent, to the extent such consent is mandatory under applicable laws. Your personal data shall not be used for purposes incompatible with those you have been informed about, unless required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

Will we share your personal data with third parties? next

We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Such third parties may be located in other countries. Necessary steps are taken prior to such transfer to ensure the data is given adequate protection as required by relevant data privacy laws and FaceorbitTM’s internal policies.

Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses (a copy of which can be obtained through the contact information included below). Any other non-EEA related transfers of data will take place in accordance with the appropriate international data transfer mechanisms and standards.

What is FaceorbitTM’s provision for sensitive data? next

We do not generally seek to collect sensitive data (also known as special categories) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term "sensitive data" refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

What are the provisions for data security? next

FaceorbitTM maintains organizational, physical and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures and guidance to monitor such arrangements, taking into account the risks associated with the various categories of data and the respective processing we undertake.

We adopt market leading security measures to protect your personal data.

Regarding your use of our websites, it is important for the users to realise that the transparency of the Internet is such that information and personal data flows 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 are intended.

Where will your personal data be processed? next

As a global organization with offices and operations spread across the world, the data we collect may be transferred or be subject to international accessibility, throughout FaceorbitTM's global business and between its entities and affiliates.

Further information on FaceorbitTM (and, if relevant, its representatives) can be found here. Any FaceorbitTM entity located outside the European Union will, in compliance with data privacy laws, be represented by FaceorbitTM.

How long will your personal data be retained by us? next

Any personal data collected is retained only as long as necessary. Specific records are maintained by the management, in accordance with retention policies and procedures, so that such data is deleted after a reasonable time according to the following retention criteria:

  • Any personal data is retained only for the duration in which the user has a relationship with FaceorbitTM (in particular, if you have an account with us).
  • The data is retained while the user’s account is active or for as long as needed to provide services to the user.
  • The data is retained for as long as needed in order to comply with our global legal and contractual obligations.

What rights are the user entitled to, with respect to the processing of your personal data? next

The user is entitled to the following rights in the circumstances and under the conditions, subject to exceptions, set out in applicable law:

  • Request access to the personal data we process about the user: This right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of the same.
  • Request a rectification of the user’s personal data: This right entitles you to have your personal data corrected, in case of inaccuracy or non-completion.
  • Object to the processing of the user’s personal data: This right entitles you to request that FaceorbitTM no longer processes your personal data.
  • Request the erasure of the user’s personal data: This right entitles you to request the erasure of your personal data, including places where such personal data is no longer purposive.
  • Request the restriction of the processing of your personal data: This right entitles you to request that FaceorbitTM only processes your personal data in limited circumstances, prior to which your consent is mandatory.
  • Request portability of your personal data: This right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to FaceorbitTM, or request for the transmission of such personal data to another data controller.

To the extent that the processing of personal data is based on the user’s consent, one has the right to withdraw such consent at any time by contacting FaceorbitTM’s Data Privacy Officer. Please note that this will not affect FaceorbitTM’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

In case, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to FaceorbitTM first, to seek resolution of any complaint. You have the right, at all times to register a complaint directly with the relevant supervisory authority or to make a claim against FaceorbitTM with a competent court (either in the country where you live, the country where you work or the country where you deem that the data privacy law has been infringed).

Contact us to exercise any of your rights.

In addition to the information set out above, the following section would describe how the personal data is used when you visit FaceorbitTM’s website:

What personal data do we gather? next

FaceorbitTM collects personal data from its website mainly in two ways:

(1) Directly, for example, when you provide personal data 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 personal data:

  • Personal data 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 personal data may provide further information as to why your personal data is needed and what use it would be put to. Provision of such data is completely at the user’s discretion.
  • Any direct correspondence by the user may be kept recorded by us.
  • We may ask you to complete surveys that we use for research purposes, though response to such surveys is voluntary.
  • Any postings, comments or other content that you upload or post to a FaceorbitTM website.
  • Our website collects personal data about your computer, including, if 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 Cookies section below for more information.

Do we include (links to) websites and programs of third parties? next

Our websites may include:

  • Links to and from the sites of our partner networks, advertisers and affiliates.
  • Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process the user’s personal data collected through such programs for their own purposes.

**We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.**

How do we use personal data that we collect from our websites? next

We use personal data for the purposes described in the aforementioned section “For which purposes and on which legal basis do we use your personal data?”. Besides, such data is also used to provide you with the information you request, process online job applications, and for other purposes that are described to the user at the point where it is collected. For example:

  • To fulfil requests for white papers, articles, newsletters or other content.
  • For surveys or research questionnaires.
  • To personalize one’s experience at our website.
  • To contact potentially interested users for market purposes.

We analyse your IP address and browser information to determine what is most effective about our website, to help us identify ways of improving.

Please see the Cookies section below for more information.

How do we use cookies (and other tracking technologies)?

In addition to the information set out above, this section describes how we use cookies and other tracking technologies, to their best possible efficiency. We analyse your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.

Please see our Cookies policy for more details. By using our website, you agree that we can place cookies and other similar technologies on your device as explained in our Cookies policy.

How do we use personal data when the user visit our offices?

In addition to the information set out above, this section describes to what use the personal data is put when the user visits FaceorbitTM offices.

Please click here to receive further details on how we process your personal data when visiting our offices (this sub-page also relates to the potential processing of your personal data through CCTV and access management systems in case such CCTV and access management systems are active.)

If you have any queries relating to our data privacy or you wish to let us know about website/marketing permissions, please contact us.

In addition to the information set out above, the following sections describe how we use such personal data for marketing purposes:

What are the sources of marketing data? next

The bulk of the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies that we share an existing business relationship with. Contact information may also be obtained from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client/other company.

Do we send targeted e-mails? next

Commercial e-mails may be sent to individuals at our client/other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mails typically include web beacons, cookies, and other similar technologies that allow us to know whether you open, read, or delete the message, and the URLs you access. When the user accesses a link mentioned in a marketing e-mail from FaceorbitTM, a cookie is used to log what pages one views and what content is download from our websites, even if the user is not registered at or signed in to our site.

Targeted e-mails from FaceorbitTM may include additional data privacy information, as required by applicable laws.

Do we maintain Customer Relationship Management (CRM) databases? next

Like most companies, FaceorbitTM uses Customer Relationship Management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client/other companies with whom we share a pre-existing business relationship or wish to develop one. The personal data used for these purposes includes relevant business information, such as:

  • Contact data,
  • Publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose),
  • User responses to targeted e-mails (including web activity following links from our e-mails),
  • Website activity of registered users of our website, and other business information included by FaceorbitTM professionals based on their personal interactions with you.

If you wish to be excluded from our CRM databases, please contact us.

Do we combine and analyse personal data? next

We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with the user (this includes information collected across our different websites, such as our careers and corporate sites and information collected when you sign up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn and Xing). We combine this data to better assess your experience with FaceorbitTM and to perform the other activities described throughout our privacy policy.

Do we share personal data with third parties? next

In addition to the third parties in the aforementioned section “Will we share your personal data with third parties?” we may share your personal data with marketing agencies.

What are your rights regarding marketing communications?

A user can exercise his right to prevent marketing communications to one by checking certain boxes on the forms, that we use to collect personal data, or by utilizing opt-out mechanisms in e-mails sent to the user. One can also exercise the right to discontinue marketing communications, or to have one’s personal data removed from our customer relationship management (CRM) databases at any time by contacting us. In such cases, we will retain minimum personal data to note that one has opted out in order to avoid contacting you again. Alternatively, one may want to use this link to inform us about their opt-out preferences.

Contact us

Please click here if:

You can also contact our Data Privacy Officer.