Last update date: April 14, 2023
This policy discloses the privacy practices for www.silversky.com (“Website”) owned and operated by SilverSky Inc. (“SilverSky”, “Us”, “We” and “Our”) and explains how We collect and use information about you through your interaction with the Website, our social media pages and other circumstances where this policy is hyperlinked (like job opportunity pages and processes).
SilverSky wants to demonstrate its commitment to your privacy and this policy informs you about what personal information is gathered and tracked from this website, how that information is used and your choices regarding use, access, and collection of such information.
This policy applies where We are acting as a controller with respect to the personal data of Our website visitors and service users; in other words, where We determine the purposes and means of the processing of that personal data.
Our website incorporates privacy controls which affect how We will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.
- What Data Do We Collect, How Do We Collect It and How Will We Use It?
- Data Security
- Retaining and Deleting Personal Data
- Your data protection rights
- Privacy policies of other websites
- How to contact us
WHAT DATA DO WE COLLECT, HOW DO WE COLLECT IT AND HOW WILL WE USE IT?
In this Section We have set out:
(a) the general categories of personal data that We may process;
(b) in the case of personal data that We did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which We may process personal data; and
(d) the legal bases of the processing.
Where you have an option, you may choose not to provide certain information to Us but doing so may limit Our ability to communicate with you or fulfill your requests.
Other than in relation to employment data (as defined below), we do not collect any special categories of personal data about you (including details about your race or ethnicity or philosophical beliefs, medical information, sexual orientation, political opinions, trade union membership, genetic and biometric data or information on your criminal convictions and offences), other than where this is voluntarily supplied by you (including by making such information manifestly public or through employment application document).
We collect and use your personal data in the following ways (and ancillary, compatible ways):
Usage – We may process data about your use of Our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics and the website CMS. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is consent OR Our legitimate interests, namely delivering, performing, managing, monitoring and improving Our website and services and contractual requirements.
Account – We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating Our website, providing Our services, ensuring the security of Our website and services, maintaining back-ups of Our databases and communicating with you. The legal basis for this processing is consent OR Our legitimate interests, namely the proper administration of Our website and business including delivering, performing, managing, monitoring and improving our services and contractual requirements.
Profile – We may process your information included in your personal profile on Our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of Our website and services. The legal basis for this processing is consent OR Our legitimate interests, namely the proper administration of Our website and business including delivering, performing, managing, monitoring and improving our services and contractual requirements.
Services – We may process your personal data that are provided in the course of the use of Our contracted services (“service data“). The service data may include name, email address, IP, asset ID, location, and device log data. The source of the service data is you or your employer. The service data may be processed for the purposes of operating Our website, providing Our services, ensuring the security of Our website and services, maintaining back-ups of Our databases and communicating with you. The legal basis for this processing is consent OR Our legitimate interests, namely the proper administration of Our website and business including delivering, performing, managing, monitoring and improving our services and contractual requirements.
Publication – We may process information that you post for publication on Our website or through Our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering Our website and services. The legal basis for this processing is consent OR Our legitimate interests, namely the proper administration of Our website and business including delivering, performing, managing, monitoring and improving our services and contractual requirements.
Enquiries – We may process information contained in any enquiry you submit to Us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you or your organization. The legal basis for this processing is consent.
Customer Relations – We may process information relating to Our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between Us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing Our relationships with customers, communicating with customers, keeping records of those communications and promoting Our products and services to customers. The legal basis for this processing is consent OR Our legitimate interests, namely the proper management of Our customer relationships.
Transaction – We may process information relating to transactions, including purchases of goods and services, that your organization enters into with Us and/or through Our website (“transaction data“). The transaction data may include your contact details, card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is Our legitimate interests, namely the proper administration of Our website and business including delivering, performing, managing, monitoring and improving our services and contractual requirements.
Notification – We may process information that you provide to Us for the purpose of subscribing to Our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent, or legitimate interests (to administer and run Our website, business and service) where the notification is a service message.
Correspondence – We may process information contained in or relating to any communication that you send to Us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is Our legitimate interests, namely the proper administration of Our website and business and communications with users.
Marketing – We may process information about you in order to send relevant marketing, and awareness communications. This data may include your name, email address, telephone number, address, age, professional title. The source of this data is subscribing to Our mailing lists or your organization being a client of SilverSky. This data may be processed for marketing of products and services and to inform you of Our latest news and blog articles. The legal basis for this processing is consent OR Our legitimate interests, namely marketing to, and awareness of, Our existing clients .
Job applications – We will process the personal data you send to Us or We receive from other sources (like recruiters and recruitment websites) in order to manage recruitment, selection and employment (including any dispute process and associated legal requirements like compliance with tax laws and fair employment reporting requirements). This data will include any information you provide to Us as part of any of the above, including during a recruitment campaign and included on your CV, covering letters and on any responses to job applications and selection processes, including your racial or ethnic origin, religious or philosophical beliefs and trade union membership “employment data”.
Disputes – We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is Our legitimate interests, namely the protection and assertion of Our legal rights, your legal rights and the legal rights of others.
Inter-Group – We may share all or any of the above data with Our group of companies. Where this happens we require all recipients to respect the security of your personal data and to treat it in accordance with the law. We do this on the basis of Our legitimate interests, including the effective and efficient operation of our business.
Professional Support – We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is Our legitimate interests, namely the proper protection of Our business against risks.
Legal compliance – In addition to the specific purposes for which We may process your personal data set out in this section, We may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which We are subject, or to protect your vital interests or the vital interests of another natural person.
When Our Company processes your order, it may send your data to, and use the resulting information from, credit reference agencies to prevent fraudulent purchases.
Notice Regarding California Consumer Privacy Act (CCPA)
To the extent you disclose personal information or personal data of California consumers or households to Us to provide Services to you, We may be considered a “service provider” as defined in the CCPA Section 1798.140(v). We acknowledge and agree that you disclose personal information and personal data to Us solely for: (i) a valid business purpose; and (ii) for Us to perform or provide Our services as set forth in an agreement by and between you and Us. We are prohibited from: (i) selling personal information and personal data if the California consumer or household has opted out of the sale of their personal information or personal data; (ii) retaining, using, or disclosing personal information or personal data for a commercial purpose other than providing services to you; (iii) retaining, using, or disclosing the personal information or personal data outside of the direct business relationship between Us and you; or (iv) using the personal information or personal data to provide services to another person or entity. We hereby certify that We understand and will comply with these obligations and restrictions in accordance with the CCPA. Furthermore, We agree to reasonably assist you in responding to any requests from a California consumer or household exercising their rights under the CCPA. For purposes of this Notice, “Personal Information” is defined in CCPA Section 1798.140(o). Further, this Notice is effective for the term of the Agreement by and between you and Us.
SilverSky has put in place appropriate security measures and technologies to prevent personal data being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Examples of our security measures include:
- Paper and other hard copies containing personal data should be secured in a locked location when not in
- Computers and other access points should be secured when not in use by logging out or
- Passwords and user ID’s should be guarded and not
- When no longer necessary for business purposes, paper and hard copies should be immediately destroyed using paper shredders or other approved devices.
- Do not leave copies in unsecured locations waiting to be shredded or otherwise
- Do not make or distribute unauthorized copies of documents and other tangible mediums containing personal
- Electronic files containing personal data should only be stored on secured computers and not copied or otherwise communicated to unauthorized individuals within or outside of If electronic files must be share outside of the organization, you must implement the appropriate controls such as encryption.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
International transfers of your personal data
In this Section, We provide information about the circumstances in which your personal data may be transferred to countries outside the UK and European Economic Area (EEA).
We and Our other group companies have offices and facilities in the UK and US. Transfers to each of these countries will be protected by appropriate safeguards. We may store, access or use your personal data in the United States or in any other country where We or Our service providers do business or maintain facilities. Therefore, We may transfer personal data between different jurisdictions. We transfer personal data in compliance with the General Data Protection Regulation and other applicable law. For example, We may use standard contractual clauses issued by the European Commission and/or the International Data Transfer Agreement(s) (“IDTA”) issued by the UK’s Information Commissioner’s Office for data transfers to data controllers and data processors established outside of the European Union, European Economic Area, Switzerland, and the UK.
The hosting facilities for Our website are situated in the US. The European Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses and/or IDTA.
Our professional partnerships include AWS, Microsoft, SentinelOne, Salesforce and HubSpot and are serviced within the UK and USA under UK and USA Law, respectively. Each such partner uses sub-processors and more information can be found in each’s website.
You acknowledge that personal data that you submit for publication through Our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
RETAINING AND DELETING PERSONAL DATA
This Section sets out Our data retention policies and procedure, which are designed to help ensure that We comply with Our legal obligations in relation to the retention and deletion of personal data.
Personal data that We process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
(a) Your personal data, including your name, email address, telephone number, address, age, professional title will be retained for a minimum period of 12 months following your initial enquiry on Our website, and for a maximum period depending on the nature of Our processing requirements. For example, if you subscribe to any of Our mailing lists you will remain subscribed until such times as you unsubscribe or request that your data be deleted.
In some cases, it is not possible for Us to specify in advance the periods for which your personal data will be retained. In such cases, We will determine the period of retention based on the following criteria:
(b) the period of retention of your personal data will be determined based on your subscription preferences. You will remain subscribed to the SilverSky emails, blogs, offers and any other emails We offer a subscription to, until such times as you actively unsubscribe from one or all of the above.
Notwithstanding the other provisions of this Section, We may retain your personal data where such retention is necessary for compliance with a legal obligation to which We are subject, in order to protect your vital interests or the vital interests of another natural person or where necessary in connection with ongoing or anticipated legal proceedings.
We may update this policy from time to time by publishing a new version on Our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We may notify you of significant changes to this policy by email.
YOUR DATA PROTECTION RIGHTS
Our company would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request Our company for copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that Our company correct any information you believe is inaccurate. You also have the right to request Our Company to complete information you believe is incomplete.
The right to erasure – You have the right to request that Our company erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that Our company restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Our company’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that Our company transfer the data that We have collected to another organization, or directly to you, under certain conditions.
If you make a request, We have thirty days to respond to you. If you would like to exercise any of these rights, please contact Us:
Call Us at: 1-800-234-2175
Or email Us: email@example.com
PRIVACY POLICIES OF OTHER WEBSITES
Our website and other SilverSky services may include links and/or may allow you to link the solutions to third-party sites, products or services. Please note that your access to and use of these third-party sites, products or services may result in the collection of or sharing of your information, including Personal Information. These third-parties have separate and independent privacy policies, and We are not responsible or liable for your interactions with such third-parties (as further described in Our Terms of Service). The option to link to such third-party sites, products or services from any SilverSky services is not an endorsement or representation regarding any third-party sites, products or services, and We encourage you to review and understand such third-parties privacy policies.
HOW TO CONTACT US
Email Us at: firstname.lastname@example.org
Call us: 1-800-234-2175
Or write to Us at:
SilverSky, 3015 Carrington Mill BLVD, Suite 400, Morrisville, NC, United States
If you have any complaints about the way SilverSky is handling your personal data, please let us know immediately. You may email us directly at email@example.com in relation to data held by us. We will respond within 30 days at the latest, unless required to respond earlier under relevant law.
If you are a data subject based in the UK or European Union, you may have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), or other competent supervisory authority of an EU member state if we collect your data outside the UK. We would appreciate the chance to deal with your concerns before you approach such bodies so would ask that you, please contact us in the first instance.
If you would like to make a complaint to the ICO, their contact details are:
By phone – 0303 123 1113
Online – https://ico.org.uk/concerns