Privacy Statement

Open iT respects your privacy. This Privacy Statement informs you about our privacy practices including details of the personal data we collect, use, disclose and transfer, as well as choices you can make and rights you can exercise in relation to your personal data. This Privacy Statement is available from a link on the footer of every Open iT web page.

This Privacy Statement applies to all Open iT-owned websites, domains, services, applications, and products, except when a privacy policy or statement specific to a particular Open iT program, product or service may supersede or be supplemented by this Privacy Statement.

1. How we use personal data

We collect personal data only if required to provide our products or services, fulfil our legitimate business purposes and/or comply with applicable laws and regulations. Depending on your relationship with Open iT we collect and process your personal data as follows:

  • Open iT Products and Services — contact details and login credentials for the following main purposes: entering into and performing agreements with you or your organization; providing support and tools to activate licenses and request support; managing and fulfilling orders; deploying and delivering products and services; conducting quality controls; operating and providing access to customer portals and hosted management services; consulting; developing and improving our products and services; and ensuring compliance with regulatory requirements.

  • Financial Operations — contact details, records of good standing and other information as may be relevant (e.g. information from 1. How we use personal data publicly available resources) for the following main purposes: providing lease, loan and other financial services; initiating credit approval process and facilitating the purchase and resale of software; and fulfilling requirements needed for regulatory compliance.

  • Sales and Marketing — contact details, identification information, profile, role and preferences, login credentials, digital activity information and other information as may be relevant (e.g. information from publicly available sources) for the following main purposes: sales and marketing, including cold calling/emailing; advertising; creating and delivering targeted adverts and offers; conducting marketing campaigns; managing contacts and preferences; generating leads and opportunities; organizing and managing webinars, trade shows, and events; and engaging in social media interactions.

  • Online Data Collection Tools — digital activity information for the following main purposes: enabling efficient use of our websites, products and services; collecting statistics to optimize the functionality of our websites, products and services; improving user experience and delivering content tailored to their interests; and improving marketing and advertising campaigns.

  • Online Forums and Surveys — contact details, login credentials, comments and feedback for the following main purposes: engaging with partners and suppliers in online forums; conducting customer satisfaction and engagement surveys.

  • Partner and Supplier Programs — contact details for the following main purposes: managing relations with partners and suppliers; engaging and delivering products and services to customers, in which case we may receive personal data directly from you or from our partners.

  • Training and Education — contact details for the main purpose of conducting trainings and education programs for customers, partners and suppliers.

  • Brand Protection Programs — contact details, login credentials and other relevant information (e.g. information from publicly available sources) for the main purpose of conducting investigations into Open iT product-related fraud, compliance, theft and/or counterfeit.

  • Security and Authentication — contact details, identification information and CCTV footage for the following main purposes: ensuring safety and security of Open iT staff and premises; login credentials, protecting the Open iT network and other digital assets; providing access to restricted areas and information assets and protecting personal data from unauthorized access.

  • Inquiries and Complaints — contact details and information included in inquiries and complaints.

Non-Open iT Websites and Social Media Features. Open iT sites or services may provide links to third-party applications, products, services or websites for your convenience or information. We may also provide social media features that enable you to share information with your social networks and to interact with Open iT on various social media sites. Open iT does not control third party sites or their privacy practices and we do not endorse or make any representations about third party sites. The personal data you choose to provide to or that is collected or shared by these third parties is not covered by this Privacy Statement. We encourage you to review the privacy policy of any site you interact with before allowing the collection and use of your personal data.


2. How we share personal data

Open iT does not sell, rent or lease personal data to others except as described in this Privacy Statement. We may share and/or disclose your personal data as follows:

Disclosure within the Open iT Group of Companies. Open iT has its headquarters in the United States of America and operates worldwide. Open iT may disclose your personal data as necessary within the Open iT group of companies in connection with how we use your personal data.

Disclosure to Third Parties. Open iT retains suppliers and service providers to manage or support its business operations, provide professional services, deliver products, services and customer solutions and to assist Open iT with marketing and sales communication initiatives. Those third parties may receive and process your personal data under appropriate instructions, as necessary to support and facilitate how we use your personal data. Suppliers and service providers are required by contract to keep confidential and secure the information they process on behalf of Open iT and may not use it for any purpose other than to carry out the services they are performing for Open iT.

Where Open iT engages with partners, resellers and/or distributors as part of its business operations, Open iT may disclose your personal data to them in order to facilitate sales and delivery of its products and services. Partners, resellers and/or distributors are required by contract to keep confidential and secure the information received from Open iT and may use it only for the said purposes, unless otherwise authorized by you or applicable laws and regulations.

Except as described in this Privacy Statement, Open iT will not share your personal data with third parties without your permission, unless to:

(i) respond to duly authorized information requests of police and governmental authorities;
(ii) comply with law, regulation, subpoena, or court order;
(iii) enforce/protect the rights and properties of Open iT; or
(iv) protect the rights or personal safety of Open iT, our employees, and third parties, or on using Open iT property when allowed, and in each case in accordance with applicable law.

Circumstances may arise where, whether for strategic or other business reasons, Open iT decides to sell, buy, merge or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of personal data to prospective or actual purchasers, or the receipt of it from sellers. It is Open iT’s practice to seek appropriate contractual protection for personal data in these types of transactions.


3. How we transfer personal data internationally and to third parties

Open iT may transfer your personal data as necessary within the Open iT group of companies and to other third parties. The recipients may be located in countries that do not provide the same level of data protection as the country in which you are located. Open iT will take steps to ensure personal data we transfer is adequately protected as required by applicable data protection laws. Where required by local law, we will request your consent to transfer your personal data.

Transfers within the Open iT Group of Companies. Open iT has an intra-company agreement on the transfer and processing of personal data within the Open iT group of companies. Open iT ensures that EEA personal data transferred and processed by Open iT companies outside the EEA is adequately protected in accordance with applicable data protection laws.

Transfers to Third Parties. With respect to transfers to third parties located in countries that do not provide an adequate level of data protection, Open iT will take appropriate safeguards.

WHO IS AN EXTERNAL THIRD PARTY

In relation to Open iT’s Data Privacy Compliance program, an external third party is defined as any company, legal entity or person who is not part of Open iT.

For companies and legal entities, this means any company and/or legal entity not owned and controlled directly or indirectly by Open iT. And for persons, this means any person, acting on his/her own behalf, who is not related to Open iT as a current employee, managing director, or board member.

WHEN IS PERSONAL DATA HANDLED/PROCESSED BY AN EXTERNAL THIRD PARTY

The situations where personal data may be handled or otherwise processed by external third parties can vary quite significantly. It includes any situation where an external third party is:

  • granted access to Open iT’s personal data, even if they have no rights or possibility of amending the personal data,
  • collecting personal data on behalf of Open iT (e.g. in connection with recruitment activities),
  • amending, using, analyzing, disclosing, sharing, or transferring personal data on behalf of Open iT,
  • providing storage facilities (e.g. hosting servers) for Open iT’s personal data,
  • performing specific outsourced business processes on behalf of Open iT, e.g. payroll, recruitment, surveys, HR, or the like, and
  • administering and/or servicing IT-systems, cloud solutions on behalf of Open iT.

4. How to manage communications and preferences

Open iT may provide you with information that complements our products and services and/or communications about our new products, services and offers. If you or your organization purchased our products or services, you may receive alerts, software updates, or responses to support requests that are part of our products and services. If you choose to receive Open iT communications, you may also choose to subscribe to receive specific newsletters and publications. In some cases, you may also choose whether to receive the information and communication by email, telephone, or post.

Manage Communication Choices. You can change your choices and preferences relating to Open iT communications by accessing the Communications Management Hub, providing your name and email address, indicating your choices, and clicking on Submit.

Unsubscribe from Communications. In the event you no longer wish to receive Open iT communications, you can unsubscribe from such communications by:

  • Following opt-out or unsubscribe link and/or instructions included in each email subscription communication;
  • Accessing Communications Management Hub and clicking on “Unsubscribe”.
  • Indicating to the caller that you do not wish receive calls and/or communications from Open iT anymore.

In the event your opt-out or unsubscribe request has not been resolved in a timely manner, please contact the Open iT Data Protection Officer with details of your name, contact information, and description of the communications you no longer wish to receive from Open iT.

Please note that these options do not apply to communications relating to the administration of orders, contracts, support, product safety warnings, or other administrative and transactional notices, where the primary purpose of these communications is not promotional in nature.


5. Automatic Data Collection Tools

How Open iT uses Automatic Data Collection Tools. Open iT web sites may use cookies, web beacons and other similar technologies (collectively, Automatic Data Collection Tools), to remember log-in details, collect statistics to optimize site functionality, improve your user experience and deliver content tailored to your interests.

Cookies may also be used when you share information using a social media sharing button on our websites. The social network will record that you have done this and may use this information to send you targeted advertisements. The types of cookies used by these companies and how they use the information is governed by their privacy policies.

When you enter your contact details on a web form on an Open iT website in order to subscribe to a service, download a white paper, or request information about Open iT products and service, your contact details may be stored in a cookie on your device. This information may then be accessed on subsequent visits to Open iT websites, allowing us to track and record the sites you have visited and the links you have clicked in order to better personalize your online experience, and future Open iT communications.

If you choose to receive marketing emails or newsletters from Open iT, we may track whether you’ve opened those messages and whether you’ve clicked on links contained within those messages through the use of web beacons and personalized URLs embedded in these communications. This would allow Open iT to better personalize future communications and limit these communications to subjects that are of interest to you.

Choices Regarding Automatic Data Collection & Online Tracking. While Open iT web sites at this time do not recognize automated browser signals regarding tracking mechanisms, such as "do not track" instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser. You can set your browser in most instances to notify you before you receive a cookie, giving you the chance to decide whether to accept it or not. You can also generally set your browser to turn off cookies. However, since cookies allow you to take advantage of some of our web sites' features, we recommend that you leave them on. If you block, turn off or otherwise reject our cookies, some web pages may not display properly or you will not be able, for instance, to use any web site services that require you to sign in.

Some of our websites may use Google Analytics cookies. Information collected by Google Analytics cookies will be transmitted to and stored by Google on servers in the United States of America in accordance with its privacy practices. To see an overview of privacy at Google and how this applies to Google Analytics, visit https://www.google.com/policies/privacy/. You may opt out of tracking by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.


6. How to access, update, or delete personal data

Open iT strives to keep your personal data accurately recorded. We have implemented technology, management processes and policies to help maintain data accuracy. In accordance with applicable laws, Open iT provides individuals with reasonable access to personal data that they provide to Open iT and the reasonable ability to review and correct it.

To protect your privacy and security, we will take reasonable steps to verify your identity before granting access to your personal data. Access, update, or deletion of your data may require a government issued photo ID (passport or driver's license) and proof of residency (e.g., copy of utility bill, phone bill, or government issued proof of residence). To view and update the personal data you provided directly to Open iT, you may contact the Open iT Data Protection Officer.


7. How we keep personal data secure

Open iT takes seriously the trust you place in us to protect your personal data. In order to protect your personal data from loss, or unauthorized use, access or disclosure, Open iT utilizes reasonable and appropriate physical, technical, and administrative procedures to safeguard the information we collect and process.

When collecting or transferring sensitive information we use a variety of additional security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. The personal data you provide us is stored on computer systems locked in controlled facilities which have limited access. Access to your information is restricted to Open iT employees or authorized third parties who need to know that information in order to process it for us, and who are subject to strict confidentiality obligations. When we transmit sensitive information over the internet, we protect it through the use of encryption, such as the Transport Layer Security (TLS), Internet Protocol Security (IPSec), or Secure Socket Layer (SSL).


8. How long we keep personal data

Typically, we keep personal data for the length of any contractual relationship and, to the extent permitted by applicable laws, after the end of that relationship for as long as necessary to perform purposes set out in this Privacy Statement, to protect Open iT from legal claims and administer our business. When we no longer need to use personal data, we will delete it from our systems and records or take steps to anonymize the data unless we need to keep it longer to comply with a legal or regulatory obligation. If you would like to receive more information about our data retention policies, please contact the Open iT Data Protection Officer.


9. Additional information for individuals in the EU, EEA and Switzerland

Our privacy practices are aligned with the requirements of the General Data Protection Regulation (GDPR). If you are located in the European Union (EU), the European Economic Area (EEA) or Switzerland, this additional information may be relevant and applicable to you.

Data controllers. Companies from the Open iT Group of Companies may act as data controllers in relation to your personal data for the processing of personal data described in this Privacy Statement. You can find the up-to-date list of the Open iT Group of Companies by clicking here. If you would like to receive more information about which Open iT entity acts as data controller for your personal data, please contact the Open iT Data Protection Officer.

Data Protection Officer. Open iT has appointed a Data Protection Officer (DPO) to comply with the GDPR. You can contact the DPO by completing the form available here or in writing to:

OPEN IT NORGE AS
Office of Legal & Administrative Affairs – ATTENTION DATA PROTECTION OFFICER
Karoline Kristiansens v. 5
N-0661 Oslo, Norway
Phone: +47 22 20 40 50

Legal Basis to Process Personal Data. We process your personal data on the following legal bases:

  • Legitimate Interest. We may process your personal data as required to pursue our legitimate business interests (provided this is not overridden by interests or rights of relevant individuals). In particular, to manage, develop and improve our products and services; support our customers and sales operations; protect our staff and assets; communicate information that supplements our products and services and ensure compliance with laws and regulations.

  • Performance of an Agreement. We may process your personal data to enter into or fulfill agreements with your or your organizations, including to deliver and manage our products and services and allow our customers to use our products, services and supporting tools.

  • Legal Obligation. We may process your personal data to comply with applicable laws and regulations, establish or exercise our legal rights. For example, in connection with legal claims, compliance, regulatory and investigative purposes.

  • Consent. We may process your personal data where you have provided your consent. In particular, where we cannot rely on an alternative legal basis or we are required by law to ask for your consent in the context of some of our sales and marketing activities, online data collection tools, or surveys. At any time, you have a right to withdraw your consent by changing your communication choices, unsubscribing from Open iT communications or contacting the Open iT Data Protection Officer.

Your Rights in Relation to Your Personal Data. You have the following rights to:

  • Request access or copies of personal data Open iT processes about you;

  • Rectify your personal data, if inaccurate or incomplete;

  • Delete your personal data, unless an exception applies. For instance, we may need to keep your personal data to comply with legal obligation;

  • Restrict the processing of your personal data, in certain circumstances. For instance, if you contest accuracy of your personal data you may request that we restrict processing of your personal data for the time enabling us to verify the accuracy of your personal data;

  • Data portability, in certain circumstances. For instance, you may request us to transmit some of your personal data to another organization if the processing is based on your consent or a contract;

  • Object to processing of your personal data, in certain circumstances. For instance, you may object to direct marketing including use of your personal data for profiling for direct marketing or where we process your personal data because we have legitimate interest in doing so.

These rights may be limited in some situations, such as where Open iT can demonstrate that Open iT has a legal requirement or legitimate interest to process your personal data.

If you would like to exercise your rights, please contact us by completing the form available here or by writing to the DPO at the address indicated in the Data Protection Officer section above.

Complaint with a Supervisory Authority. If you consider that the processing of your personal data infringes the GDPR, you have a right to lodge a complaint with a supervisory authority in the country where you live, or work, or where you consider that data protection rules have been breached.

If Open iT processes your personal data on behalf of an Open iT customer, then we will, in the first instance, refer your complaint to our customer to handle.


10. How to contact us

We value your opinions. If you have any questions about our Privacy Statement, any concerns or complaint regarding our collection and use of your personal data or wish to report a possible breach of your privacy, please contact the Open iT Data Protection Officer or write to us at the appropriate address below. We will treat your requests and complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to address your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.

Canada, Latin America and US:

OPEN IT, INC.
Office of Legal & Administrative Affairs – ATTENTION DATA PROTECTION OFFICER
Two Park Ten Place
16300 Katy Freeway
Houston, TX 77094
Phone: 281-599-3400
Fax: 707-760-4575

EMEA

OPEN IT NORGE AS
Office of Legal & Administrative Affairs – ATTENTION DATA PROTECTION OFFICER
Karoline Kristiansens v. 5
N-0661 Oslo, Norway
Phone: +47 22 20 40 50

APAC

OPENIT PHILIPPINES, INC.
Office of Legal & Administrative Affairs – ATTENTION DATA PROTECTION OFFICER
Doña Aurora Boulevard
Gulang-Gulang
Lucena City 4301
Philippines
Tel: +63 42 710 8566


11. Changes to this Privacy Statement

If we modify this Privacy Statement, we will post a revised version with an updated revision date at the privacy link on the footer of every Open iT web page.


Last Updated: July, 2018
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