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).
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.
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.
Kurtosys may collect and use Individual Users’ personal information for the following purposes:
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.
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.
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.
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.
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.
134 Fifth Avenue, 3rd Floor, New York NY 10011
Tel: +1 646 838 2030
77 Kingsway, London WC2B 6SR
Tel: +44 (0)800 029 1410
This document was last updated in May, 2018.