Privacy Policy

We collect personal data only for specified, explicit, and legitimate purposes. The purposes for data collection are clearly communicated at the point of collection.

We limit personal data collection to what is directly relevant and necessary to accomplish the specified purposes. No excessive data is collected.

All data processing activities have a valid lawful basis under applicable data protection laws, including consent, contractual necessity, legal obligation, vital interests, public task, or legitimate interests.

When relying on consent as the lawful basis, we ensure it is freely given, specific, informed, and unambiguous. Clear affirmative action is required, and withdrawal mechanisms are provided.

Processing of special category data (e.g., health, biometrics) only occurs when additional legal requirements are met, with explicit consent or when necessary for specific legal purposes.

Personal data is not used for purposes incompatible with the original collection purposes without obtaining additional consent or establishing a new lawful basis.

We maintain accurate and up-to-date personal data, with processes to correct or delete inaccurate or incomplete data without delay.

Personal data is kept in identifiable form only as long as necessary for the specified purposes, with defined retention periods and secure deletion protocols.

We implement measures to ensure personal data remains adequate, relevant, and limited to what is necessary for the processing purposes.

We provide meaningful information about any solely automated processing that produces legal or significant effects, with rights to obtain human intervention and contest decisions.

We implement appropriate technical and organizational measures to ensure personal data remains confidential, including encryption, access controls, and secure transmission protocols.

We protect personal data against accidental or unlawful destruction, loss, alteration, or damage through regular backups, checksums, and system monitoring.

We maintain reliable access to personal data through resilient systems, disaster recovery plans, and business continuity measures while ensuring appropriate security.

We implement role-based access controls, least privilege principles, and multi-factor authentication to restrict access to personal data based on job requirements.

We have established procedures to detect, investigate, and report personal data breaches to supervisory authorities and affected individuals within required timeframes.

Individuals have the right to obtain confirmation of processing and a copy of their personal data in a commonly used electronic format.

Individuals may request correction of inaccurate personal data and completion of incomplete data without undue delay.

Individuals may request deletion of personal data when it's no longer necessary, consent is withdrawn, or other legal grounds apply, with certain exceptions.

Individuals may request limited processing of their data during accuracy disputes, unlawful processing claims, or when data is needed for legal claims.

Individuals may receive their provided data in a structured, commonly used format and transmit it to another controller where technically feasible.

We provide clear, concise, and easily accessible privacy notices at all data collection points, including identity of controller, purposes, legal basis, and rights.

We use layered notice approaches where appropriate, providing key information immediately with options to access more detailed explanations.

We provide contextual privacy information at the point of data collection, particularly for sensitive data or unexpected uses.

All privacy communications use clear, straightforward language appropriate for the intended audience, avoiding legal or technical jargon.

This privacy policy is permanently available on our website and provided in alternative formats upon request.

We have appointed a Data Protection Officer responsible for monitoring compliance, providing advice, and serving as a contact point for data subjects and authorities.

We maintain detailed records of all processing activities, including purposes, data categories, recipients, retention periods, and security measures.

We conduct Data Protection Impact Assessments for high-risk processing activities and consult with authorities when residual risks remain.

We conduct due diligence on all processors, establish data protection agreements, and monitor compliance throughout the contract term.

We provide regular privacy and security training to all employees based on their role and access to personal data.

We transfer personal data to third countries only when the destination has an adequacy decision or with appropriate safeguards like Standard Contractual Clauses.

We conduct assessments of third country laws and supplement safeguards as needed to ensure essentially equivalent protection for transferred data.

Where required by law, we maintain data storage and processing within specific geographic boundaries as stipulated by local regulations.

We clearly inform individuals about international data transfers in our privacy notices, including the legal mechanisms used and how to obtain copies.

We carefully select cloud service providers that meet our data protection standards and configure services to maintain compliance with transfer requirements.

We implement additional protections for children's personal data, including age verification and parental consent mechanisms where required.

We maintain separate policies and procedures for employee data processing, with clear workplace monitoring guidelines and internal reporting channels.

Personal data used for research purposes is subject to additional safeguards like pseudonymization and institutional review board approval where appropriate.

We provide clear opt-in mechanisms for marketing communications and honor opt-out requests promptly, maintaining suppression lists as needed.

We provide granular cookie consent options and respect user preferences for non-essential tracking technologies, with easy preference updates.

We maintain a compliance framework that maps to multiple privacy regulations (GDPR, CCPA, etc.) with jurisdiction-specific implementations as needed.

We honor California consumer rights including access, deletion, and opt-out of sales, with specific mechanisms for submitting verifiable requests.

We have designated an EU representative as required under Article 27 of the GDPR for organizations without an EU establishment.

We cooperate with regulatory audits and maintain evidence of compliance through documentation, logs, and other verifiable records.

We protect employees who report potential privacy violations from retaliation and provide confidential reporting channels.

We maintain a version history of this policy with change logs documenting material modifications and their effective dates.

Policy changes undergo legal review and executive approval, with consideration of stakeholder impacts and implementation requirements.

Material policy changes are communicated to affected individuals through appropriate channels with advance notice when practicable.

Temporary policy exceptions require documented justification, risk assessment, and approval with defined expiration dates.

We regularly review and update this policy based on operational changes, regulatory developments, risk assessments, and stakeholder feedback.