Effective on: 8/31/2021
Introduction and Scope
[The Coronation Group] acts as an agent, also known as a data processor, for the Personal Data we process for our customers when providing our Services. This means that our customers determine the type of Personal Data they provide for us to process on their behalf. We typically have no direct relationship with the individuals whose Personal Data we receive from our customers.
Basis of Processing
We may process your Personal Data on the basis of:
the need to perform a contract with you;
our legitimate interests or those of a third party, such as our interest in marketing our Services;
the need to comply with the law; or
any other ground, as required or permitted by law.
How We Receive Personal Data
We may receive your Personal Data when:
you provide it directly to us as part of using our Services;
our customers (including their employees, contractors, and other representatives of the company) provide it to us;
our service providers provide it to us.
Categories of Personal Data
We may process the following types of Personal Data: [THE FOLLOWING SHOULD BE EXPANDED OR ADJUSTED DEPENDING ON SCOPE OF DATA COLLECTED]
biographical information, such as company name or first and last name in the case of a person; and
contact information, such as email addresses and postal addresses.
Purposes of Processing
We may process your Personal Data for the purposes of:
enabling the use of the Services;
responding to your requests or questions; and
sending you email marketing communications about our business which we think may interest you.
When the purposes of processing are satisfied, we will delete the related Personal Data within one year.
Sharing Personal Data with Third Parties
We may share Personal Data with our service providers, who process Personal Data on our behalf, and who agree to use the Personal Data only to assist us in providing our Services or as required by law. Our service providers may provide: [THE FOLLOWING SHOULD BE EXPANDED OR ADJUSTED DEPENDING ON SCOPE OF SERVICES BEING USED]
application hosting services;
cloud storage services;
advertising and marketing services; and
Other Disclosure of Your Personal Data
We may disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our subsidiaries or affiliates, but only if necessary for business purposes, as described in the section above.
We reserve the right to use, transfer, sell, and share aggregated, anonymous data, (which does not include any Personal Data) about individuals whose Personal Data we process in connection with providing our Services, for any legal business purpose. These purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.
If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.
We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Most of the cookies placed on your device through our Services are first-party cookies, since they are placed directly by us. Other parties, such as Google, may also set their own (third-party) cookies through our Services. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.
If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all of our Services’ features. For more information, please visit https://www.aboutcookies.org/.
You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visit https://allaboutdnt.com/. Please note that our Services do not have the capability to respond to “Do Not Track” signals received from web browsers.
Data Integrity & Security
We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing. This includes unauthorized access, disclosure, alteration, or destruction.
Access & Review
If we process your Personal Data, you may have the right to request access to (or to update, correct, or delete) such Personal Data. You may also have the right to ask that we limit our processing of such Personal Data, as well as the right to object to our processing of such Personal Data. You may also have the right to data portability.
Privacy of Children
The Services are not directed at, or intended for use by, children under the age of 13.
Changes to this Policy
If we make any material change to this Policy, we will post the revised Policy to this web page. We will also update the “Effective” date. By continuing to use our Services after we post any of these changes, you accept the modified Policy.
If you have any questions about this Policy or our processing of your Personal Data, please write by email at email@example.com