Privacy Policy

Kurtosys Systems Inc. complies with the US-EU Privacy Shield Framework and the US-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.  Kurtosys Systems Inc. has certified that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/list.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Kurtosys is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC).

This privacy policy applies to this site and all sites created with products and services offered by Kurtosys.

Personal identification information

We may collect personal identification information from Individual Users in a variety of ways, including, but not limited to, when Individual Users visit our sites, register on the sites, place an order, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our sites. Individual Users may be asked for, as appropriate, name, email address, phone number, or location. Individual Users may, however, visit our sites anonymously. We will collect personal identification information from Individual Users only if they voluntarily submit such information to us. Individual Users can always refuse to supply personal identification information, except that it may prevent them from engaging in certain sites’ related activities.

Non-personal identification information

We may collect non-personal identification information about Individual Users whenever they interact with our sites. Non-personal identification information may include the browser name, the type of computer, and technical information about Individual Users’ means of connection to our sites, such as the operating system and the Internet service providers utilized or other similar information.

Web browser cookies

Our sites may use “cookies” to enhance user experience. Individual Users’ web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. Individual Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. If they do so, note that some parts of those sites may not function properly.

How we use collected information

Kurtosys may collect and use Individual Users’ personal information for the following purposes:

  • To improve customer service
    Information you provide helps us respond to your customer service requests and support needs more efficiently.
  • To create a user profile for authentication and preferences
    We may use your personal information to provide identification of your account and preferences as well as details that will enable security and authentication checks for your personal safety.
  • To personalize user experience
    We may use information in the aggregate to understand how our users as a group use the services and resources provided on our sites.
  • To improve our Site
    We may use feedback you provide to improve our products and services.
  • To send periodic emails
    We may use the email address to send user information and updates pertaining to an order. It may also be used to respond to inquiries, questions, and/or other requests. If a user decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the user would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

How we protect your information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of personal information, username, password, transaction information and data stored on our Sites. We secure this on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All data is protected using encryption at rest and in transfer, such as the Secure Socket Layer (TLS) protocol.

Sharing your personal information

We do not sell, trade, or rent any Individual Users’ personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.  We may use third party service providers to help us operate our business and the sites or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Kurtosys is potentially liable.

Third party websites

Individual Users may find advertising or other content on our sites that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our sites. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our sites, is subject to that website’s own terms and policies.

Complaints

In compliance with the Privacy Shield Principles, Kurtosys commits to resolve complaints about our collection or use of your personal information.  Individuals in the European Union with inquiries or complaints regarding our Privacy Shield policy should first contact Kurtosys using the contact details below or using the contact us page on this web site.

Kurtosys has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. Under certain circumstances, individuals may have a right to invoke binding arbitration to resolve a dispute with Kurtosys regarding the processing or transfer of their personal information under the Privacy Shield.

Kurtosys commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities regarding human resources data transferred from the EU in the context of the employment relationship.

Right to access, change or delete personal information

  • Right to Access.
    Individual Users have the right to know what personal information about them is included in our databases and to ensure that such data is accurate and relevant for the purposes for which Kurtosys and our Customers collected it. Individual Users may review their own personal information stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and Kurtosys policies. Upon reasonable request and as required by the Privacy Shield Principles, Kurtosys allows Individual Users access to their personal information, in order to correct or amend such data where inaccurate. Individual Users may edit their personal information by logging into their account profile or by contacting Kurtosys by phone or email. In making modifications to their personal information, Individual Users must provide only truthful, complete, and accurate information. To request erasure of personal information, Individual Users should submit a written request to Kurtosys.
  • Requests for Personal Data.
    Kurtosys will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: i) legally binding request for disclosure of the personal information by a law enforcement authority unless prohibited by law or regulation; ii) requests received from the Individual User. If Kurtosys receives a request for access to his/her personal information from a Data Subject, then, unless otherwise required under law or by contract with such Individual User, Kurtosys will refer such Data Subject to the Individual User.
  • Satisfying Requests for Access, Modifications, and Corrections.
    Kurtosys will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate personal information.

Changes to this privacy policy

Kurtosys has the discretion to update this privacy policy at any time in a manner that is consistent with the requirements of the Privacy Shield. When we do, we will revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using this site, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our site. Your continued use of the site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact Kurtosys Systems at:

134 Fifth Avenue, 3rd Floor, New York NY 10011
Tel: +1 (646) 380 3877

or

25 Wellington Street, 3rd Floor, London WC2E 7DA
Tel +44 (0)20 7836 3476

This document was last updated in January, 2017.