Saltmine USA Inc. and its affiliates (together, “Saltmine”, “we”, “us” or “our”) respects the privacy of its clients, partners, employees, and websites visitors, and is committed to protecting the personal data you may share with us (these and any others with respect to whom we collect personal data, shall collectively be referred to as “User”, “client”, “you” or “Data Subjects”).
It also describes the choices available to you regarding our use of your Personal Data and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
We are transparent about our practices regarding the information we collect, use, maintain and process and describe our practices in this Policy. Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it.
For the purposes of EU General Data Protection Regulation (the “GDPR”) and other applicable privacy laws, Saltmine is a data controller (“Controller”) (or a “business” under other laws) in relation to the Personal Data of our clients and prospective clients, employees and website visitors. However, we will usually be a data processor (“Processor”) (or a “service provider”) in relation to the Personal Data of client employees provided to us by our clients.
Summary: we collect various categories of Personal Data in order to meet our contractual obligations, and also to meet various legitimate interests, such as fraud prevention and marketing.
We collect data about you in connection with your transactions with us, or in processing data for our clients. We also collect data about Saltmine employees and website visitors. One type of data collected is non-identifiable and anonymous information (“non-Personal Data”). We also collect several categories of Personal Data, as described below.
When you visit the Website our servers automatically record information that your browser sends. In other words, when you are using the websites, we are aware of it and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below. This includes technical information and behavioral information such as your device IP address, browser type and version, operating system type and version, screen resolution, location data related to the geographic location of your workstation, laptop, mobile device or other digital device on which the Saltmine websites are used, time zone setting, language preferences or the webpage visited prior to entering Saltmine’s Website, your ‘clickstream’ on Saltmine’s website, methods used to browse away from a page, pages of our Website that you visit, the time spent on those pages, information you search for on our Website, access times and dates, and other statistics. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding Website usage. This statistical information is not otherwise aggregated in such a way that would identify directly any particular user of the system. We likewise may place cookies on your browsing devices (see ‘Cookies’ section below).
When you wish to contact us or use some of the Website’s features, you may be asked to provide certain Personal Data (for example, your name and e-mail address). We receive and store any information you knowingly and voluntarily provide to us when you publish content, fill any online forms on the Website or otherwise contact us or communicate with us. Saltmine uses this information to offer Saltmine’s Services and support. When required, this information may include the following:
● Personal details such as name, country of residence, etc.
● Contact information such as email address, address, phone number, etc.
● Any other materials you willingly submit to us such as articles, images, feedback, etc.
Summary: we collect Personal Data when you or your organization send it to us, or when a vendor, distributor or other business partner, sends it to us; we collect Personal Data through our website and Services, and through our interactions with you.
We collect Personal Data required to provide Services when you register interest, or when you provide us such information in meetings or conferences, by entering it manually or automatically including through our online assessments, in the course of preparing a contract or otherwise in engaging with us. We also collect Personal Data when you call us for support, in which case we collect the information you provide us.
We also collect Personal Data through your use of our websites, as detailed above.
Summary: we process Personal Data to meet our obligations, protect our rights, and manage our business.
In order to make our Website and Services available to you, to improve our Services or to meet our contractual, ethical and legal obligation, we need to collect and use certain Personal Data. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Some of the information we collect is directly from you via our Website. However, we may also collect Personal Data about you from other sources. Any of the information we collect from you will remain accurate complete and relevant for the stated purposes for which it was processed, including for example:
Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract:
● carrying out our obligations arising from any contracts entered into between you and Saltmine and/or any contracts entered into with Saltmine and to provide you with the information, support and Services that you request from Saltmine;
● verifying and carrying out financial transactions in relation to payments you make in connection with the Services.
Processing which is necessary for the purposes of the legitimate interests pursued by Saltmine or by a third party of providing an efficient and wide-ranging service to clients:
● notifying you about changes to our Services and/or to financial products we manage;
● contacting you to give you commercial and marketing information about events or promotions or additional products or Services offered by Saltmine which may be of interest to you, including in other locations;
● soliciting feedback in connection with the Services;
● tracking use of Saltmine Services to enable us to optimize them;
● for security purposes and to identify and authenticate your access to the login zone.
Processing which is necessary for compliance with a legal obligation to which Saltmine is subject:
● compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, anti-money laundering, tax related obligations, and for crime prevention and prosecution in so far as it relates to our staff, clients, service providers, facilities etc;
● if necessary, we will use Personal Data to enforce our terms, policies and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity thefts and any other service misuse, and to take any action in any legal dispute and proceeding.
Summary: we share Personal Data with our service providers, partners, and group companies, and authorities where required.
Depending on the requested Services or as necessary to complete any transaction or provide any service you have requested, we may share your information with trusted third parties that work with us, any other affiliates and subsidiaries we rely upon to assist in the operation of the Website and Services available to you. We do not share Personal Data with unaffiliated third parties. These third parties assist us in providing the Services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time. These third parties may also include analytics and search engine providers that assist us in the improvement and optimization of our websites, and our marketing. These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. We may share your Personal Data for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Data. These third parties are given Personal Data they need only in order to perform their designated functions, and we do not authorize them to use or disclose Personal Data for their own marketing or other purposes.
We periodically add and remove third party providers. At present services provided by third-party providers to whom we transfer Personal Data include also the following: – Website analytics; – Document management and sharing services; – Client ticketing and support; – On-site and cloud-based database services; – CRM software; – Data security, data backup, and data access control systems; – Our lawyers, accountants, and other standard business software and partners.
We will disclose any Personal Data we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and Personal Data will likely be among the assets transferred. For avoidance of doubt, Saltmine may transfer and disclose non-Personal Data to third parties at its own discretion.
Summary: we retain Personal Data according to our data retention policy, as required to meet our obligations, protect our rights, and manage our business. We will retain and use your Personal Data only for the period necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We will also retain Personal Data to meet any audit, compliance and business best-practices.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.
Summary: we transfer Personal Data within and to the EEA, USA and elsewhere, with appropriate safeguards in place.
We transfer Personal Data to locations outside of the EEA, including in particular USA and Singapore, in order to: – store or backup the information; – enable us to provide you with the Services and products and fulfill our contract with you; – fulfill any legal, audit, ethical or compliance obligations which require us to make that transfer; – facilitate the operation of our group businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights; – to serve our clients across multiple jurisdictions; and – to operate our affiliates in an efficient and optimal manner.
Summary: depending on the law that applies to your Personal Data, you may have various data subject rights, such as rights to access, erase, and correct Personal Data, and information rights. We will respect any lawful request to exercise those rights.
You may, under certain circumstances, exercise certain rights regarding your information processed by us. In particular, you depending on the law that applies to your Personal Data, you may have the right to do the following: (i) withdraw consent where you have previously given your consent to the processing of your information; (ii) object to the processing of your information under certain circumstances; (iii) learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) verify the accuracy of your information and ask for it to be updated or corrected; (v) under certain circumstances, restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) under certain circumstances, obtain the erasure of your Personal Data from us; (vii) receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
It is clarified for the removal of doubt, that where Personal Data is provided by a client being the data subject’s employer, such data subject rights will have to be effected through that client, the data subject’s employer. In addition, data subject rights cannot be exercised in a manner inconsistent with the rights of Saltmine employees and staff, with Saltmine proprietary rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectified by data subjects. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Saltmine USA Inc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
● You have the right to request access to your Personal Data that we store and have the ability to access your Personal Data.
● You have the right to request that we correct any Personal Data you believe is inaccurate. You also have the right to request us to complete the Personal
● Information you believe is incomplete.
● You have the right to object to our processing of your Personal Data.
● You have the right to seek restrictions on the processing of your Personal Data.
● When you restrict the processing of your Personal Data, we may store it but will not process it further.
● You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
● You also have the right to withdraw your consent at any time where Saltmine USA Inc. relied on your consent to process your Personal Data.
● You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data.
For more information, please contact your local data protection authority in the European Economic Area (EEA). If the supervisory authority fails to deal with a complaint, you may have the right to an effective judicial remedy.
Any requests to exercise your rights can be directed to Saltmine USA Inc. (privacy[at]saltmine.com). Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you. Please note that Personal Information may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Information, depending on technical commercial capability. Such information may continue to be used by Saltmine.
We do not knowingly collect any Personal Information from children under the age of 16. If you are under the age of 16, please do not submit any Personal Information through our Website or Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Data through our Website or Service without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to us through our Website or Service, please contact us at: privacy[at]saltmine.com, as soon as possible.
In many cases, these tags/files lead to the use of your device’s processing or storage capabilities. Some of these tags/files are set by Saltmine itself, others by third parties; some only last as long as your browser session, while others can stay active on your device for a longer period of time.
These tags/files can fall into several categories: (i) those that are necessary for functionality or Services that you request or for the transmission of communication (functionality tags/files); (ii) those that we use to carry out website performance and audience metrics (analytics tags/files) and (iii) the rest (tracking across a network of other websites, advertising, etc.) (other tags/files).
Internet browsers allow you to change your cookie settings, for example to block certain kinds of cookies or files. You can therefore block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of the website, due to the fact that some may be functionality cookies. For further information about deleting or blocking cookies, please visit: https://www.aboutcookies.org/how-to-delete-cookies/
Functionality and analytical tags/files do not require your consent. For other tags/files, however, we request your consent before placing them on your device. You can allow cookies in your browser settings and using our website cookie management too.
To consult the list of cookies which we use on our website, please check your browser’s settings. Instructions: https://www.wikihow.com/View-Cookies
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, this Website is not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Data.
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Data, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
In the event we become aware that the security of the Website has been compromised or users Personal Data has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities.
Saltmine shall act in accordance with its policies and with applicable law to promptly notify the relevant authorities and data subjects in the event that any Personal Data processed by Saltmine is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. Saltmine shall promptly take reasonable remedial measures.
You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.
Saltmine’s data protection officer (DPO) may be contacted at: privacy[at]Saltmine.com
This document was last updated on May 4, 2022.