GDPR POLICY

Astuto Technologies LLC Privacy & GDPR Policy

1.0/ OUR CORE PRINCIPLES REGARDING USER PRIVACY AND DATA PROTECTION

  • User privacy and data protection are inviolable human rights
  • We have a duty of care to people contained within our data
  • Data is a liability: it should only be collected and processed when absolutely necessary
  • We despise spam in all its forms
  • We will never sell, rent or otherwise distribute or make public any personal information

2.0/ RELEVANT LEGISLATION

Alongside our business and internal computer systems, this site
https://astutotechnologies.com/ is designed to comply with the following national and international legislation with regards to data protection and user privacy:

  • US Law including state laws applicable to your state.
  • UK Data Protection Act 1988 (DPA)
  • EU Data Protection Directive 1995 (DPD)
  • EU General Data Protection Regulation 2018 (GDPR)

This site’s compliance with the above legislation, all elements of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0 below) for clarification.

3.0/ PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT.

This website collects and uses personal information for the following reasons:

3.1. Site Visitation Tracking

Like most websites, this site uses Google Analytics (GA) to track user interaction.

We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to track their journey through the website.

Although GA records data such as your approximate geographical location, device, internet browser and operating system, none of this information personally identifies you to us.
GA also records your computer’s IP address which could be used to personally identify you but Google does not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).

GA makes use of cookies, details of which can be found on Google’s developer guides.

For your information, our website uses the different implementation of GA.

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages on this website.

3.2. Email Links

Should you choose to contact us using an email link like this one info@astutotechnologies.com, none of the data that you supply will be stored by this website or passed to/be processed only by any of the third party data processors defined in section 6.0 below.

Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.

3.3. Contact Forms

Should you choose to contact us using the contact form on our Site or Contact page the email address that you submit to us will be stored in STserver Networks platform in the ‘Contacts’ database, which we use when contacting you. We consider STserver Networks to be a third party data processor (see section 6.0 below). The email address that you submit will be stored within this website’s own database but not in any of our internal computer systems.

Your email address will remain within the STserver Networks ‘Contacts’ database on our website for as long as we continue to use the STserver Networks platform or until you specifically request removal from the list.

You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email (info@astutotechnologies.com). When requesting removal via email, please send your email to us using the email account that you used on the contact us form.

3.4. Email Newsletter

If you choose to join our regular newsletter mailings (which is sent via email), the email address that you submit to us will be stored in our STserver Networks website platform in the ‘Shout Out’ database, which we use for our email marketing. We consider STserver Networks to be a third party data processor (see section 6.0 below). The email address that you submit will be stored within this website’s own database but not in any of our internal computer systems.

Your email address will remain within the STserver Networks ‘Shout Out’ database on our website for as long as we continue to use the STserver Networks platform for email marketing or until you specifically request removal from the list.

You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email info@astutotechnologies.com). When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.

While your email address remains within the STserver Networks ‘Shout Out’ database, you will receive occasional newsletter-style emails from us.

4.0/ ABOUT THIS WEBSITE’S SERVER

This website is hosted in data center in the United States.

From time to time, we may transfer hosting from one location to another. Notwithstanding the above, our platform complies with the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles. Our provider guarantees that the platform will be compliant with the new regulations from May 2018.

All traffic (transferal of files) between this website and your browser is encrypted and delivered over HTTPS.

5.0/ OUR THIRD-PARTY DATA PROCESSOR

We use STserver Networks to process personal data on our behalf.

Neither STserver Networks or www.astutotechnologies.com/ will ever ask for any sensitive information.

Your data which is encrypted is as follows:

  • Personal data (address data, telephone number, event details, etc.)

We provides the Customer Engagement platform we use to provide you with information about Astuto Technologies LLC Services and to accept your information requests.

What STserver Networks does to ensure data protection to all our customers?

  • STserver Networks employs full-time security consultants, dedicated to the security of our customer information.
  • STserver Networks is certified under the EU-US Privacy Shield Framework and the Swiss-US privacy Shield Framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, and therefore adheres to the Privacy Shield Principles.

STserver Networks was carefully chosen to comply with the legislation set out in section 2.0.
Both our third parties are based in the USA and are EU-U.S Privacy Shield compliant.

6.0/ DATA BREACHES

We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

7.0/ SOCIAL MEDIA PLATFORMS

Communication, engagement, and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate/engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

8.0/ SHORTENED LINKS ON SOCIAL MEDIA

This website and its owners through their social media platform accounts may share web links to relevant web pages. By default, some social media platforms shorten lengthy URLs (web addresses).

Users are advised to take caution and good judgment before clicking any shortened URLs published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine URLs are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

9.0/ LINKS TO OTHER WEBSITES

Our website may contain links to other websites run by other organizations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

10.0/ 16 AND UNDER

We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.

11.0/ TRANSFERRING YOUR INFORMATION OUT OF EUROPE

As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

12.0/ WHOM TO CONTACT IF YOU HAVE QUERIES OR COMPLAIN?

If you have any queries or complaints you can write to us at: info@astutotechnologies.com

13.0/ COOKIES

This website uses cookies to store information on your computer. Cookies are small text files located in browser directories. Some of these cookies are essential to make our website work and others help us to improve by giving us some insight into how the site is being used. In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our Services. There are two types of cookies (both used on STserver Networks sites):

  • Session (Transient) cookies: these cookies are erased when you close your browser, and do not collect information from your computer. They typically store information in the form of a session identification that does not personally identify the user.
  • Persistent (Permanent/Stored) cookies: these cookies are stored on your hard drive until they expire (i.e based on a set expiration date) or until you delete them. These cookies are used to collect identifying information about the user, such as Web surfing behavior or user preferences for a specific site.

14.0/ CHANGES TO OUR PRIVACY POLICY

We keep this Policy under regular review. This Policy was last updated in December 2018.

This privacy policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes.

Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the changelog below.

Policies updated
12/12/2018