Electra Data Dashboard Privacy Policy

We respect the privacy of every person who visits dashboard.electrainfo.com (the "Website" or "Site") and who uses the services that we make available from the Site (our "Services") and we are committed to ensuring a safe online experience.

PURPOSE OF THIS POLICY

This privacy policy ("Privacy Policy") explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information.

This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Website Terms of Use.

WHO WE ARE AND WHAT DO WE DO?

The Site and our Services are operated by Electra Information Systems, Inc., ("Electra," "we", "us" or "our").

HOW TO CONTACT US

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by:

Attention: Privacy Policy Officer
Electra Information Systems, Inc.
381 Park Avenue South, Room 1413
New York, New York, 10016

WHAT PERSONAL INFORMATION DO WE COLLECT?

Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our products and services and develop and market new products and services; (iii) carry out requests made by you on the Site; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of us or third parties, including our other clients and users of the Site; (viii) provide support for the provision of our Services; and (ix) use as otherwise required or permitted by law.

Fulfilment of requests.
We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services. We may use the contact details you have provided to us so that we can fulfil requests for information and other matters related to our products and services. This includes your attendance at events hosted by us, questions or requests regarding our products and services.

Who do we share your personal information with for this purpose?
Except as otherwise set forth herein, we will not share your personal information with third parties.

What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you.

Client service inquiries.
Our Site uses various user interfaces to allow you to request information about our products and services: these include printed and electronic inquiry forms and a telephone inquiry service. Contact information may be requested in each case, together with details of other personal information that is relevant to your inquiry. This information is used in order to enable us to respond to your requests.

Who do we share your personal information with for this purpose?
Except as otherwise set forth herein, we do not share your personal information for this purpose.

What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you.

Your feedback about our products and services.
From time to we may contact you to invite you to provide feedback about our products and services in the form of online, postal or other surveys. We use this information to help us improve the quality of service provided by our staff. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.

Who do we share your personal information with for these purposes?
Except as otherwise set forth herein, we do not share your personal information for this purpose.

What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

Customer insight and analysis.
We may analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services.

Where you have given your consent (where lawfully required), we may use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Sites, or from your mobile. This includes the following:

Our web pages and e-mails may contain "cookies" "web beacons" or "pixel tags." ("Tags"). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail messages, we may use a "click-through URL" linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Where we have your consent to do so, we may use your location data for customer insight purposes.

By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of information our registered users like to see.

We may also use this information to help us with the selection of future product and service lines, website design and to remember your preferences.

We may also use this information for marketing purposes (see the marketing section below for further details).

Who do we share your personal information with for these purposes?
We may share your personal information with third party service providers to assist us with customer insight analytics.

What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.

We will only use your location data for customer insight purposes where we have your consent to do so.

Marketing communications.
We may carry out the following marketing activities using your personal information:

Postal marketing.
We may use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your address details, to send you marketing communications by post.

Who do we share your personal information with for these purposes?
We may share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.

What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal information for postal marketing.

Email marketing
We may use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

Who do we share your personal information with for these purposes?
We may share your personal information with third party email marketing providers who assist us in delivering our email marketing campaigns to you.

What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

Online personalized advertising
We may use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalized online advertising.

Who do we share your personal information with for these purposes?
We share your personal information with third party service providers who assist us with our online personalized advertising campaigns.

What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

Business administration and legal compliance.
We use your personal information for the following business administration and legal compliance purposes:

in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes?
We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

What is our legal basis?
Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

HOW DO WE OBTAIN CONSENT?

Where our use of your personal information requires your consent, you can provide such consent:

OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES

Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our "Cookie Policy" for more details.

THIRD PARTY LINKS AND SERVICES

Our Sites contain links to third party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We keep your personal information for a period of 6 years from the date of our last interaction with you.

If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it sooner.

CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

HOW TO ACCESS YOUR INFORMATION AND YOUR RIGHTS

You have the following rights in relation to the personal information we hold about you:

Your right of access.
If you ask us, we'll confirm whether we're processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete, you're entitled to have it rectified. If we've shared your personal information with others, we'll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.

Your right to erasure.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we've shared your personal information with others, we'll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.

Your right to restrict processing.
You can ask us to 'block' or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won't stop us from storing your personal information though. We'll tell you before we lift any restriction. If we've shared your personal information with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.

Your right to data portability.
With effect from May 25, 2018, you have the right, in certain circumstances, to obtain personal information you've provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we are:

Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it's based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we've handled your personal information, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. For the purposes of the UK, the supervisory authority is the Information Commissioner's Office (ICO), UK Information Commissioner's Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113

U.S.-E.U. PRIVACY SHIELD

We comply with the U.S.-E.U. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information obtained from European Union member countries and the United Kingdom and transferred to the United States. For more information on how we process personal information transferred from the European Union, under the Privacy Shield Principles, click here.

Electra participates in the EU-U.S. Privacy Shield framework ("Privacy Shield") issued by the U.S. Department of Commerce. Electra commits to comply with the Privacy Shield Principles with respect to Consumer Personal Data that Electra receives from the European Union member countries and the United Kingdom in reliance on the Privacy Shield. This Policy describes how we implement the Privacy Shield Principles for Consumer Personal Data.

"Consumer" means any natural person who is located in the EU, but excludes any individual acting in his or her capacity as an Employee.

"Controller" means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

"Employee" means any current, former or prospective employee, temporary worker, intern or other non-permanent employee of any subsidiary or affiliate of Electra, who is located in the EU.

"Personal Data" means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Electra in the U.S. from the EU, and (iii) recorded in any form.

"Privacy Shield Principles" means the Principles and Supplemental Principles of the Privacy Shield.

"Processor" means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

"Sensitive Data" means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.

"Supplier" means any supplier, vendor or other third party located in the EU that provides services or products to Electra.

Types of Personal Data Electra Collects
Electra collects Personal Data directly from Consumers. This collection occurs, for example, when a Consumer visits Electra's website. Electra may use this information for the purposes indicated in Electra's Privacy Policy.

The types of Consumer Personal Data Electra collects includes: contact information, such as name, postal address, email address and telephone number; and Personal Data in content consumers provide on Electra's website and other data collected automatically through the website (such as IP addresses, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our website, and dates and times of website visits).

In addition, Electra obtains Personal Data, such as contact information and financial account information, of its Suppliers' representatives. Electra uses this information to manage its relationships with its Suppliers, process payments, expenses and reimbursements, and carry out Electra's obligations under its contracts with the Suppliers.

Electra also may obtain and use Consumer Personal Data in other ways for which Electra provides specific notice at the time of collection.

Electra's privacy practices regarding the processing of Consumer Personal Data comply with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

Notice
Electra provides information in this Privacy Shield section and Electra's Privacy Policy about its Consumer Personal Data practices, including the types of Personal Data Electra collects, the types of third parties to which Electra discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data, and how to contact Electra about its practices concerning Personal Data.

Relevant information also may be found in notices pertaining to specific data processing activities.

Choice
Electra generally offers Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the Privacy Shield Principles, Electra obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact Electra as indicated below regarding Electra's use or disclosure of their Personal Data. Unless Electra offers Consumers an appropriate choice, Electra uses Personal Data only for purposes that are materially the same as those indicated in this Privacy Shield section.

Electra shares Consumer Personal Data with its affiliates and subsidiaries. Electra may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors Electra has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. Electra also reserves the right to transfer Personal Data in the event of an audit or if Electra sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

This Privacy Shield section and the Electra's Privacy Policy describe Electra's sharing of Consumer Personal Data.

Except as permitted or required by applicable law, Electra provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Electra requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (iii) notify Electra and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.

With respect to transfers of Consumer Personal Data to third-party Processors, Electra (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Electra's obligations under the Privacy Shield Principles, (v) requires the Processor to notify Electra if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Electra remains liable under the Privacy Shield Principles if Electra's third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Electra proves that it is not responsible for the event giving rise to the damage.

Security
Electra takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

Data Integrity and Purpose Limitation
Electra limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. Electra does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes, Electra takes reasonable steps to ensure that the Personal Data Electra processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Electra relies on its Consumers to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact Electra as indicated below to request that Electra update or correct relevant Personal Data.

Subject to applicable law, Electra retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer.

Access
Consumers generally have the right to access their Personal Data. Accordingly, where appropriate, Electra provides Consumers with reasonable access to the Personal Data Electra maintains about them. Electra also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. Electra may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer's privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting Electra as indicated below.

Recourse, Enforcement and Liability
Electra has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Electra conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Electra makes about its Privacy Shield privacy practices are true and that Electra's privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Consumers may file a complaint concerning Electra's processing of their Personal Data. Electra will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact Electra as specified below about complaints regarding Electra's Consumer Personal Data practices.

If a Consumer's complaint cannot be resolved through Electra's internal processes, Electra will cooperate with JAMS pursuant to the JAMS International Mediation Rules, available on the JAMS website. JAMS mediation may be commenced as provided for in the relevant JAMS rules. The mediator may propose any appropriate remedy, such as deletion of the relevant Personal Data, publicity for findings of noncompliance, payment of compensation for losses incurred as a result of noncompliance, or cessation of processing of the Personal Data of the Consumer who brought the complaint. The mediator or the Consumer also may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over Electra. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Electra's compliance with the Privacy Shield Principles.

How to Contact Electra
To contact Electra with questions or concerns about this Privacy Shield section or Electra's Consumer Personal Data practices, please contact us by:

DO NOT TRACK DISCLOSURES

"Do Not Track" is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org. At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties' direct marketing purposes. To make such a request, please contact us by e-mail or post using the contact details set out in this Privacy Policy.

Pursuant to California Civil Code Section 1798.83(c)(2), we will not share your personal information with third parties for those parties' direct marketing use unless you elect that we do so.

CHANGES TO THIS PRIVACY POLICY

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.