1. Document control
1.1 Version control
Keeper Solutions is managed & tracked within the Process & Policy Library.
1.2 Document classification
The information is of a public nature and not confidential.
2. Policy overview
3. Personal data
Keeper Solutions attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure that when you deal with us, your personal data is in good hands. Keeper Solutions protects your personal data in accordance with applicable laws and our data privacy policies. In addition, we maintain the appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage.
3.1 Categories of personal data we collect
We collect personal data of our employees, potential employees, clients, suppliers, business contacts, shareholders and website users. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.
Except for certain information that is required by law, or as part of the services we provide, your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that 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 you may not be able to use certain tools and systems which require the use of such personal data.
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 the person has given you his/her consent for sharing the information with Keeper Solutions.
The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or apply for a role within Keeper Solutions or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers and vendors.
3.2 Purposes for processing your personal data
We use your personal data only where required for specific purposes. The below lists the purposes for which Keeper Solutions uses your personal data and an overview of the legal basis for each such purpose. Purposes: Managing our contractual and/or employment relationship with you (Legal basis: Necessary for the performance of a contract to which you are a party). Recruitment (Necessary for our legitimate interests for ensuring that we recruit the appropriate employees). Facilitating communication with you (Necessary for our legitimate interests for ensuring proper communication and emergency handling within the organisation). Operating and managing our business operations (Necessary for our legitimate interests for ensuring the proper functioning of our business operations).Complying with legal requirements (Necessary for the compliance with a legal obligation to which we are subject). Monitoring your use of our systems (Necessary for our legitimate interests of avoiding noncompliance and protecting our reputation). Improving the security and functioning of our website, networks and information (Necessary for our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure). Marketing our products and services to you (Necessary for our legitimate interests for ensuring that we can conduct and increase our business).
Keeper Solutions will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws. We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorised by law.
3.3 Your personal data and third parties
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. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and our 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. Any other non-EEA related transfers of your personal data, will take place in accordance with the appropriate international data transfer mechanisms and standards.
3.4 Processing of sensitive data
While Keeper Solutions does not seek to collect sensitive data (also known as special categories) through our sites, in the event 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).
3.5 Data security measures
Keeper Solutions maintains organisational, physical and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.
3.6 Personal data transfers
Personal data we collect may be transferred or be accessible internationally throughout Keeper Solution’s business and between its entities and affiliates. Any such transfers that take place will be done in accordance with the applicable data privacy laws.
We are committed to adequately protect your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred outside of the EEA or other countries deemed adequate by the EU.
3.7 How long will your personal data be retained by us?
3.8 Your rights with respect to the processing of your personal data
You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
• Request access to the personal data we process about you: 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 that personal data
• Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete
• Object to the processing of your personal data: this right entitles you to request that Keeper Solutions no longer processes your personal data
• Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes
• Request the restriction of the processing of your personal data: this right entitles you to request that Keeper Solutions only processes your personal data in limited circumstances, including with your consent
• 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 Keeper Solutions, or request from us to transmit such personal data to another data controller.
To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by submitting a formal request to Keeper Solutions. Please note that this will not affect our 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.
4. Personal data when you visit Keeper Solutions website
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 are 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 a Keeper Solutions site (such as Facebook, Twitter, LinkedIn etc).
• Our website collects personal data 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.
4.1 Links to websites and programs of third parties
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 your personal data collected through such programs for their own purposes.
4.2 How do we use personal data that we collect from our websites?
We use personal data for the purposes described in the section “Purposes for processing your personal data?” above, as well as 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. For example:
• To fulfil your requests for white papers, articles, newsletters or other content
• For surveys or research questionnaires
• To personalise your experience at our website
• To contact you for marketing purposes where you have agreed to this
• When applying for a role within Keeper Solutions.
5. Personal data for marketing purposes
5.1 Sources of our 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.
5.2 Marketing e-mails
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. 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 Keeper Solutions, 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 Keeper Solutions may include additional data privacy information, as required by applicable laws.
5.3 Customer Relationship Management (CRM) databases
Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want 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), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by Keeper Solutions~ professionals based on their personal interactions with you.
5.4 Combining and analysing data
5.5 Your rights regarding marketing communications
You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilising opt-out mechanisms in e-mails we send to you. You can also exercise the right to discontinue marketing communications to you, or to have your personal data removed from our marketing databases at any time by contacting us. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.
7. Changes to this policy
8. Contact us
Please contact us if you have a general question about how Keeper Solutions protects your personal data • If you wish to exercise your rights in relation to your personal data rights • If you wish to make a complaint about our use of your data.
Keeper Solutions Ireland Head Office
Oakhampton, Newport, Co. Limerick
Keeper Solutions Croatian Head Office
Ivana Lučića 2a, Zagreb