SLI Systems Site Visitor Privacy Policy

Welcome to the Customer Site Visitor privacy policy of SLI Systems, Inc. and its affiliates [SLI Systems (UK) Limited and SLI Systems (Japan) K.K.]. This policy provides details of our processing of data that is collected from users of our customer websites (‘Visitor Information’)

SLI is a leading provider of site search, navigation, and other e-commerce optimization services. Your privacy is our priority and for this reason on this page we have outlined what information we collect about you, how we use it and where we store it.

References to ‘you’ and ‘your’ are references to individual users and site visitors interacting with the websites of SLI’s customers.

We have tried to make everything which follows as clear and as simple as possible, but if you have questions you can contact us and we will be happy to help. Please find our contact details at the end of this policy.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY
  11. EU-US PRIVACY SHIELD
  1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy:

This policy will deal with the way that data is collected by the websites of our customers (‘Customer Websites’), through our use of cookies, identifiers and other technologies when an individual interacts with a Customer Website.

This policy provides specific information regarding our processing of Visitor Information collected through the tracking of cookies and other technologies.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Processor

SLI is the processor on behalf of our Customers of the personal data collected in the circumstances described in this Privacy Policy. SLI is collectively referred to as “Company”. The Companyis made up of different legal entities.This privacy policy is issued on behalf of the members of the SLI group of companies so when we mention SLI, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the SLI group of companies responsible for processing your data.

Where we collect and process personal data relating to employees, agents, officers, workers and contractors of our customers, those of our commercial partners and visitors to our website (Individuals), we do so as a controller. For more information regarding how we collect and process Individuals, please see our Privacy Policy, here.

If you have any questions about this privacy policy, please contact us using the details set our below:

Contact details

Our full details are:

ATTN: Data Protection Officer

S.L.I. Systems, Inc.

78 – 106 Manchester Street

Christchurch 8011

New Zealand

privacy@sli-systems.com

You 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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We may change this policy from time to time. Although we will strive to ensure that any such changes are small, and we will inform our customers if we intend to materially change the way in which we use your data. We recommend that you consult this privacy policy regularly for updates.

  1. THE DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different types of data about you, which we have grouped together below as follows:

  • Technical Data: Includes Internet Protocol (IP) address, browser information and preferences.
  • Usage Data: Includes information about how you use any Customer Website, products and services.
  • Cookies: We use “cookies” and similar analytics-driven technologies to track interaction with Customer Websites. Where a cookie is stored on your device, we assign a unique cookie ID to that device.

We also collect, use and share Aggregated Datasuch as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Dataabout you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. HOW IS YOUR PERSONAL DATA COLLECTED

Data collection through our Customers’ Websites

SLI collects and records information about users’ visits to and use of Customer Websites through the use of industry-standard cookies and web beacons on Customer Websites. Cookies and web beacons exchange data between our servers and each user’s computer, based on instructions from our Customers.

In other words, we collect information regarding users only as enabled and permitted by our Customers. For example, at the direction of a Customer, when a user visits or purchases a product from a Customer Website, we generally collect and record such information as the user’s Internet Protocol (IP) address, the user’s browser and operating system, the website from which the user came, the pages on the Customer Website that the user visits and the date and time of the visit, the products and other information displayed on the pages the user visits, the links the user clicks, the search terms the user enters and information about other interactions between the user and Customer Website (such as what products the user adds to shopping carts and whether the user purchases the contents of shopping carts).

This information is not linked to any personally identifiable information and is not used by SLI to personally identify the user.

Visitor Information is collected through Customer Websites or by our Customers and their partners. We rely on Customers and such partners to ensure that appropriate information is provided to applicable users regarding our collection, use and disclosure of Visitor Information as set out in this policy and that each user is made aware of the lawful basis for such processing.

4. HOW WE USE YOUR PERSONAL DATA

Although the actual practices by our Customers will be set out in their privacy policies, our Customers may typically use and disclose the Visitor Information for the following purposes:

  • • To analyse trends relating to Customer Websites;
  • • To better understand how users interact with Customer Websites;
  • • To monitor aggregate usage by users on Customer Websites;
  • • To monitor web traffic routing on Customer Websites;
  • • To improve Customer Websites and to create web properties and applications that are easier to use and are more appealing to users;
  • • To enable third party contractors to assist such Customers with the foregoing;
  • • To assist Customers in using and understanding Visitor Information, including by providing Customers with related reports and data summarizing;
  • • To improve the quality of our services and other services that SLI provides to its Customers.

Except as described in this policy, SLI does not rent, sell, share, distribute or disclose Visitor Information to parties other than our Customers except when we have express permission from the applicable Customer or when we reasonably believe that we are required to do so by law or to establish or exercise our legal rights or defend against legal claims.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, collected on behalf of our Customers, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To estimate the number of unique users interacting with a Customer Website(a) Technical
(b) Cookies
(c) Usage
  1. Such processing is necessary for our legitimate interests (to assist our customers in understanding approximately how many end users interact with their websites); or
  2. Where our Customers have obtained your consent to our processing of your personal data, on the basis of such consent.
To improve the user’s experience on the Customer Website(a) Technical
(b) Cookies
(c) Usage
  1. Such processing is necessary for our legitimate interests (to assist our clients in providing more relevant search and navigation pages, product suggestions, automatic search phrase completion); or
  2. Where our Customers have obtained your consent to oue processing of your personal data, on the basis of such consent.
To track the user’s browsing activity, patterns and preferences to enable our customers to understand how users interact with their website.(a) Technical
(b) Cookies
(c) Usage
  1. Such processing is necessary for our legitimate interests (to assist our clients in providing a personalized search experience, malicious and web spider detection); or
  2. Where our Customers have obtained your consent to our processing of your personal data, on the basis of such consent.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please refer to our cookie policy  for further details.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may disclose your data to third parties such as:

  • Other members of our group of companies;
  • Authorised third-party service providers who provide IT and administration services to us to help us to provide our services;
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; and
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

  1. INTERNATIONAL TRANSFERS

We share your personal data with other companies within our group. This will involve transferring your data outside the European Economic Area (EEA). Some of our external third-party service providers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data adequate protection.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide an equivalent level of protection to personal data shared between the Europe and the US.
  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.

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.

SLI takes reasonable precautions to protect personal data relating to Individuals which is processed and collected by SLI. SLI follows generally accepted industry standard security measures to secure such personal data and protect it from unauthorized access or against loss, misuse or alteration by third parties. SLI maintains personal data behind a firewall.

Although we make good faith efforts to store personal data in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of personal data during its transmission or its storage on our systems.

Further, while we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information.

We do not warrant or represent that personal data will be protected against, loss, misuse, or alteration by third parties.

  1. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

  • Request access to your personal data:this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This is commonly known as a “data subject access request”.
  • Request correction of your personal data:this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data: this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You can also ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
  • Object to processing of your personal data:where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing your personal data:this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request transfer of your personal data:we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. (Note: this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.)

If you wish to exercise any of the rights set out above, please contact us.

Please note, where we process your information for statistical purposes, certain of the above rights will not be available to you. Please contact us for further information on which of the above rights will not apply to our processing of personal data for statistical purposes.

What we may need from you

Where we are not able to determine with any degree of certainty whether the information requested by you relates exclusively to you, our disclosure of such information to you may pose a privacy risk to a third party (for example, where a cookie is associated with a device used by more than one person). We will assess each request to exercise any of the rights listed above individually on its merits and will disclose the requested information where we are satisfied that such disclosure does not represent a privacy risk to any third party.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. GLOSSARY

Lawful Basis

Legitimate Interestmeans the interest of SLI in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contractmeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligationmeans processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the SLI Group and who are based [the United Kingdom, the United States, New Zealand, Japan and Australia] and provide IT and system administration services and undertake leadership reporting.

External Third Parties

  • Service providers acting as processors based in the UK, USA, Australia, Japan and New Zealand who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • EU-US Privacy Shield Appendix

Commitment to Privacy Shield Framework

SLI complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield.  SLI has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under 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/

Independent Recourse Mechanism

In compliance with the Privacy Shield Principles, SLI commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact SLI at: privacy@sli-systems.com

SLI has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers  for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Onward Transfers

SLI has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. SLI shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless SLI proves that it is not responsible for the event giving rise to any damage.

Investigatory and Enforcement Powers

The Federal Trade Commission has jurisdiction over SLI’s compliance with the Privacy Shield.