This Privacy Statement applies to GCS software products and services, hereafter referred to as “Products” that link to or reference this Statement. Because GCS understands the importance and sensitivity of personal data, this Privacy Statement exists to protect our customers’ and their users’ legal rights. Customers and their users are those who have accepted the terms and conditions of the GCS End User Licensing Agreement and are hereafter referred to as “You” and “Your”. Within this Statement GCS will outline the type(s) of data we collect, how we store it, how we use it, and who we share it with. We will also cover the options that are available to You regarding privacy permissions and personal information corrections/updates.
Collection of Your Personal Information
We may collect data, including personal information, about you as you use our Products in accordance with the terms and conditions of the End User License Agreement. “Personal information” is any information that can be used to identify an individual, and may include name, address, email address, phone number, login information (account number, password), marketing preferences, social media account information, or payment card number. If we link other data with your personal information, we will treat that linked data as personal information. We also collect personal information from trusted third-party sources and engage third parties to collect personal information to assist us.
We collect personal information for a variety of reasons, such as:
- Processing orders and payment transactions
- Sending marketing communications
- Creating an account
- Enabling the use of certain Product features
- Personalizing your experience
- Providing customer service
We and the third parties we engage may combine the information we collect from you over time and across our Products with information obtained from other sources. This helps us improve its overall accuracy and completeness, and also helps us better tailor our interactions with you.
If you choose to provide GCS with a third party’s personal information (such as name, email, and phone number), you represent that you have the third party’s permission to do so. Examples include forwarding reference or marketing material to a friend or sending job referrals. Third parties may unsubscribe from any future communication following the link provided in the initial message or contacting Contact Us. In some instances, GCS and the third parties we engage may automatically collect data through cookies, web logs, web beacons, and other similar applications.
Uses of Your Personal Information
- We may use your personal information for the purposes of operating our business, delivering, improving, and customizing our Products, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law. Some of the ways we may use personal information include:
- Delivering a Product you have requested
- Analyzing, supporting, and improving our Products and Your user experience
- Personalizing websites, newsletters and other communications
- Sending communications to you, including for marketing or customer satisfaction purposes, either directly from GCS or from our partners
You can edit your communication preferences at any time. See Your Choices and Selecting Your Communication Preferences below.
Your Choices and Selecting Your Communication Preferences
We give you the choice of receiving a variety of information related to our Products. You can manage your communication preferences through the following methods:
- By following the instructions included in each promotional email from us to unsubscribe from that particular mailing.
- By sending us a message Contact Us
- For short message services (“SMS Services”), by replying “STOP”, “END”, or “QUIT” to the SMS text message you have received.
These choices do not apply to service notifications or other required communications that are considered part of certain Products, which you may receive periodically unless you stop using or cancel the Product in accordance the terms and conditions shown in the End User License Agreement. With your permission, we may also share your personal information with GCS business partners or vendors, so they may send you information about products or services that may be of interest to you. To opt-out of GCS sharing with third parties for their marketing purposes, please send an email to: Contact Us.
By using our websites, Solutions, or otherwise providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use. For example, if we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our websites, by sending an email, or otherwise contacting you.
Sharing Your Personal Information
We may share your personal information with third parties for the purposes of operating our business, delivering, improving, and customizing our Products, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent.
We may share personal information in the following ways:
- Within GCS and any of our worldwide subsidiaries for purposes of data processing or storage.
- With GCS business partners or vendors, so that they may share information with you about their products or services. To opt-out of GCS sharing with third parties for their marketing purposes, please send an email to Contact Us.
- With business partners, service vendors, authorized third-party agents, or contractors to provide a requested Solution, service or transaction. Examples include, but are not limited to: processing of orders and credit card transactions, hosting websites, hosting seminar registration, assisting with sales-related efforts or post-sales support, and providing customer support.
- In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.
- In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation or legal process.
- With law enforcement officials, government authorities, or other third parties as necessary to comply with legal process or meet national security requirements; protect the rights, property, or safety of GCS, its business partners, you, or others; or as otherwise required by applicable law.
- In aggregated, anonymized, and/or de-identified form which cannot reasonably be used to identify you.
- If we otherwise notify you and you consent to the sharing.
Security of Your Personal Information
We intend to protect the personal information entrusted to us and treat it securely in accordance with this Privacy Statement. GCS implements physical, administrative, and technical safeguards designed to protect your personal information from unauthorized access, use, or disclosure. We also contractually require that our suppliers protect such information from unauthorized access, use, and disclosure. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal information you provide to us.
Retention of Personal Information
We will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.
Like many websites, GCS uses automatic data collection tools, such as cookies, embedded web links, and web beacons. These tools collect certain standard information that your browser sends to our website. Examples include your browser type and the address of the website from which you arrived at our website.
They may also collect information about:
- Your Internet Protocol (IP) address. This is a number automatically assigned to your computer or device whenever you connect to the Internet. It is a unique address assigned by your Internet service provider or IT department on a TCP/IP network. Among other things, the IP address allows web servers to locate and identify your device.
- Clickstream behavior. This includes, for example, the pages you view and the links you click. These tools help make your visit to our website easier, more efficient, and more valuable by providing you with a customized experience and recognizing you when you return.
Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different from blocking or deleting cookies, as browsers with a “do not track” feature enabled may still accept cookies.
No industry standard currently exists on how companies should respond to “do not track” signals, although one may develop in the future. GCS websites do not currently recognize and respond to “do not track” signals. If we do in the future, we will describe how in this Privacy Statement.
Consent to Transfer, Processing and Storage of Personal Information
We may transfer your personal information to GCS in the United States of America, to any GCS subsidiary worldwide, or to third parties and business partners as described above that are located in various countries around the world. By using our Products or providing any personal information to us, where applicable law permits, you consent to the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different.
GCS safeguards and enables the global transfer of personal information in a number of ways:
- APEC Privacy Certification
GCS’s global privacy program, described in this Privacy Statement, complies with the Asia Pacific Economic Cooperation (APEC) Cross-Border Privacy Rules System (CBPRs). The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. More information about the APEC Privacy Framework and CBPRs can be found here. Our certification applies to our business processes across our global operations that process and transfer personal information to/from our affiliates around the world. To view our certification, please visit the validation page by clicking on the TRUSTe seal.
- EU-US and Swiss-US Privacy Shields
GCS Systems Inc. and its US-based subsidiaries: Acano LLC, AppDynamics LLC, Broadsoft, Inc., GCS OpenDNS LLC, GCS Systems Capital Corporation, GCS WebEx LLC, CliQr Technologies LLC, CloudLock LLC, Jasper International Services LLC, Jasper Technologies LLC, Meraki LLC, and Scientific-Atlanta LLC (collectively “GCS-US”) participates in and has certified compliance with the EU-US and Swiss-US Privacy Shield Frameworks and Principles as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU), the United Kingdom (UK), and Switzerland, respectively. GCS-US is committed to subjecting all personal data received from European Union (EU) member countries, the UK, and Switzerland, in reliance on the EU-US and Swiss-US Privacy Shield Frameworks, to the Frameworks’ applicable Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about these Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield site.
GCS-US is responsible for the processing of personal data it receives, under these Privacy Shield Frameworks, and subsequently transfers to a third party acting as an agent on its behalf. GCS-US complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, the UK, and Switzerland, including the onward transfer liability provisions. In certain situations, GCS-US may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
With respect to personal data received or transferred pursuant to these Privacy Shield Frameworks, GCS-US is subject to the regulatory enforcement powers of the US Federal Trade Commission.
- EU Binding Corporate Rules – Controller
GCS’s global privacy program and policies have been approved by the Dutch, Polish, Spanish, and other relevant European privacy regulators as providing adequate safeguards for the protection of privacy, fundamental rights, and freedoms of individuals for transfers of personal information protected under European law. GCS’s Binding Corporate Rules – Controller (BCR-C) provide that transfers made by GCS worldwide of European personal information benefit from adequate safeguards.
If you have an unresolved privacy concern related to personal data processed or transferred by GCS pursuant to the CBPRs and/or Privacy Shield that GCS has not addressed satisfactorily, please contact (free of charge) our U.S.-based third party dispute resolution provider by clicking here. Under certain conditions more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Your California Privacy Rights
GCS qualifies for the alternative option. We have a comprehensive privacy statement, and provide you with details on how you may either opt-out or opt-in to the use of your personal information by third parties for direct marketing purposes. Therefore, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year.
How to Contact Us
Updates to this GCS Privacy Statement
We may update this Privacy Statement from time to time. If we modify our Privacy Statement, we will post the revised version here, with an updated revision date. You agree to visit these pages periodically to be aware of and review any such revisions. If we make material changes to our Privacy Statement, we may also notify you by other means prior to the changes taking effect, such as by posting a notice on our websites or sending you a notification. By continuing to use our website after such revisions are in effect, you accept and agree to the revisions and to abide by them.