CIGNON (collectively, “CIGNON,” “We,” and “Us”) takes your privacy extremely seriously. This statement (“Statement”) explains what data and information we collect, how and why we collect it, and how we store, use, disclose, and keep information about you and your interactions with us secure. These interactions include when you use our solutions, when you register or attend any CIGNON event, webinar, trade show, sales, or marketing activities, downloads or use our global helpdesk or other digital assets, register and participate in our online community like using our forums or online training, you reply to an CIGNON survey, and/or if you use the CIGNON platform, any of our products and/or services, including any trial version (collectively the “Services”) in any manner.

Our websites and the Services are not intended for individuals use in their personal, family or household capacity. Accordingly, we treat all personal information we collect through the website as pertaining to individuals in their business capacity, and not their personal capacity.

What information about you do we collect and how do we do it?

CIGNON collects data to operate effectively and provide our Services to you.

1. Data provided by You directly: You provide some of this data directly, like when you create an CIGNON account in our community to participate in the forums, subscribe to blog updates, administer your organization’s licensing account, register for an CIGNON event, or download digital assets like eBooks and reports from our website, access our Solutions on Microsoft Azure, or fill out a Contact Request form.
2. Job Applicants. When visit the careers portion of our websites, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to communicate with you, to operate and improve our business, and as otherwise necessary for compliance, fraud prevention, and safety purposes.
3. Usage data collected automatically: We also get some information by recording how You interact with Our products by, for example, using technologies like cookies and receiving usage data from the CIGNON platform used by You.
4. Additional data from third parties: We also obtain data from third parties to whom You’ve provided your information and you’ve given Your consent to be transferred to Us. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the data. These third-party sources may include: data brokers from which we purchase data to supplement the data we collect; service providers that help us determine a location based on your IP address in order to customize certain products to your location; and CIGNON Partners with which we engage in joint marketing and sales activities.

When you are asked to provide personal data, you may decline. However, if you choose not to provide data that is necessary for us to provide Services, you may not be able to use those Services.

The data We collect depends on the consent You’ve provided and on the context of your interactions with CIGNON, the choices you make, including your privacy settings, and the Services you use. The data we collect can include the following:

• Name and contact data. We collect your first and last name, email address, postal address, phone number, company and position, and other similar contact data.
• Credentials. We collect passwords, password hints, and similar security information used for authentication and account access to our Services.
• Usage data. We collect data about your device and how you and your device interact with CIGNON and our Services.
• Location data. For products with location-enhanced features, we collect data about your location, such as a location derived from your IP address or data that indicates where you are located with less precision, such as at a city or postal code level.
• Content. We collect content of your files and communications when necessary to provide you with the Services You use. For example, if You post a comment or a file using Our community, forums or blog, We need to collect the content of that comment or file to display it to You and the other users of the same Services.

We also collect information You provide to Us when You contact Us about the Services and the content of messages You send to Us, such as requested feedback and product reviews You write, or questions and information You provide for customer support. When you contact Us, such as for customer support, phone conversations, or chat sessions with Our representatives may be monitored and recorded.

CIGNON may also receive information about You from other sources, including third parties from whom We have purchased data, and combine this information with information We already have about You. This helps us to update, expand, and analyze our records, identify new customers, and create more tailored content to provide Services that may be of interest to You.

Why do We collect Your data?

1. Processing Your order: We use relevant personal information described above to process and deliver Your order, and to notify You of the status of your order.
2. To provide customer support: If You contact our customer service (or vice versa), We will use personal information such as Your order information and contact history to process Your request and provide You with the best service possible. We will process Your personal information in this way if it is necessary for the performance of a contract with Us or if it is required for Us to comply with any legal obligations. If it is not necessary to process Your personal data for either of these reasons, We will process it as it is necessary for the purposes of our legitimate interests in ensuring We can provide the best service possible.
3. To engage with you in relation to the programs or communities you decide to join: We will use Your personal information to provide You with the Services You have requested from Us. This will, if applicable, include the use of Your personal information for submission and publication (on our website or a third-party’s) in relation to Our Services, using Your contact details for events and using information like your location for our mobile apps. We will process your personal information in this way if it is necessary for the performance of a contract with Us. If it is not necessary for the performance of such a contract, we will process it as it is necessary for the purposes of our legitimate interests in providing these Services appropriately and ensuring they function correctly. To the extent that we process location data, we do this on the basis of Your consent to receiving these Services, and we will not process location data before You have provided your consent to us doing so.
4. Marketing: When you sign up to receive CIGNON emails, create an CIGNON single sign on, become a member of Our community, order or provide feedback on a Service, or use our website, we will use your personal information to create a profile based on the information we hold about you. This is necessary for the purposes of our legitimate interests in ensuring we have accurate information about you in one place. We create your profile in accordance with your preferences in order to provide you with the best personalized experience, to send you personalized marketing messages and newsletters and for opinion research purposes, such as:
   • What kind of information: The way you interact with our brand across all the different channels described above (e.g. the website, apps, social media and marketing messages we send you) and the information we collect in that regard from each of these channels provides us valuable information about your interests and preferences. This insight gives us the opportunity to offer you the best CIGNON experience possible. To learn about you and your interests, we analyse your interactions with Us using various kinds of information, as set out above. In particular, we may combine the information we collect with information we lawfully obtain from third parties. This is necessary for the purposes of our legitimate interests in ensuring that we provide you the most appropriate offers for products and to personalize your experience. You can opt-out of us combining your personal information with the information lawfully collected from third parties through your account settings page or by contacting us using the contact details set out below. If you have given us your consent to send you marketing communications or if we are permitted by law to send such communications without obtaining your consent, we use the information that you have provided to us when interacting with us for sending you personalized marketing messages about CIGNON Services. In some instances we will also aggregate your personal information with that of other individuals, to create comprehensive reports about how customers use our Services, and experience our brand. This is necessary for the purposes of our legitimate interests in analysing our brand and determining how to improve our Services.
   • What kind of channels: We will send direct marketing communications to you via the channel you choose, such as email, phone, or social media. We ask for your consent, where required by applicable law, in order to use the contact details you have provided to us to send our personalized marketing communications.
   • What kind of messages: The messages we will send you will be personalized and tailored to your individual preferences and interests. We use analytics in order to generate such personalized messages. These analytics will process your personal information and place you in marketing segments, which determine the content of the messages and the offers you will receive from us. These direct marketing messages may contain information about our Services, promotions, and news. We personalize these messages because it is necessary for the purposes of our legitimate interests in ensuring that we provide the most appropriate information. We will, in certain circumstances, also use the channels for opinion research (such as to ask if you would like to participate in a survey) and to learn about your experience and improve your experience with CIGNON, including by sending you personalized messages.
   • Re-targeting: Our Solutions, website and apps use re-targeting technologies, which we will only use after you have provided your consent. This enables us to show our visitors, who were already interested in our Services, advertisements from us on partner websites. We believe that the display of personalized, interest-based advertising is more interesting and relevant to our customers than advertising that does not have a personal connection. Re-targeting technologies analyse the information we collect about your interactions with each Us as described in relation to marketing above and information obtained from other parties, including your cookies, and display advertisements based on your past web-surfing behavior. We will process your data for re-targeting purposes with your explicit consent. Please click here for further information on cookies and instructions on how to disable re-targeting. Note that our sites generally are not configured to respond to web browser do-not-track signals.
   • Ads: We also work with non CIGNON companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect personal information about your visits to our websites or apps and your interaction with our communications, including advertising. They will only collect this information to the extent you have consented to the placement of cookies for marketing purposes. Please click here for further information on cookies and instructions on how to change your cookie preferences.
5. Enrichment of our data: Where we have obtained your personal information from various sources we will combine this information in certain circumstances in order to enrich our understanding of your requirements and preferences in relation to our Services. For example, we may combine information you have provided us directly with information collected automatically, such as metadata or IP addresses or where we have collected anonymous browsing data through the use of cookies, we may later determine that this data relates to your browsing history and combine that data with the existing information we hold on you. We may also combine this information with other information (both personal information and anonymized) that we have lawfully obtained from third parties. We may use the information we hold to correlate your interactions with us via one device (such as a browser on a computer) with your interactions with us via another device (such as an app on a phone). Specifically, we may carry out any of these exercises to be able to send you more personalized marketing or to prepare more effective marketing campaigns. This is necessary for the purposes of our legitimate interests to ensure that we provide you the most appropriate offers for products and to personalize your experience. You can opt-out of us combining your personal information with the information lawfully collected from third parties through your account settings page or by contacting us using the contact details set out below.
6. Conducting analytics: We will use the personal information we hold about you (as well as pseudonymized or anonymized information generated from your personal information) to carry out analysis and research. We carry out all such analysis and research on the basis that it is necessary for the purposes of our legitimate interests in understanding our customers and ensuring that our products meet the needs of our customers.
7. Analyzing our business: We will use your personal information (including by anonymizing and aggregating it with other customers’ personal information) for sales, supply chain, and financial analysis purposes, to determine how We are performing, and where improvements can be made and where necessary to report back to our parent or affiliate group companies. This is necessary for the purposes of our legitimate interests in understanding how our business is performing, and considering how to improve our performance.

What are your rights regarding the information collected and processed?

With regard to your information that is collected and/or processed by CIGNON, you may exercise the following rights:

• Right of access: You may request CIGNON to confirm if information about you is processed. If such is the case, you will receive access to your information.
• Right of rectification: If our information about you is incorrect, you may request CIGNON to rectify your information. This includes the right to have incomplete information completed, taking into account the purpose of the processing.
• Right to erasure: You may request CIGNON to erase your information, for instance if the information is unlawfully processed, or if you have withdrawn your consent.
• Right to restrict processing: You may request CIGNON to restrict the processing of your information, if (i) the information is inaccurate, (ii) the processing is unlawful, (iii) you need us to retain the information after the retention period for a legal claim, or (iv) you have objected to the processing and a verification of our legitimate interests is pending.
• Right to data portability: You may request CIGNON to provide you with an electronic file of your information, or to transfer your personal data to a third party if such is technically feasible.

How is your information used?

Where you have provided consent or requested a service of access to an App, we may use your information to:

• process orders that You have submitted;
• carry out our obligations arising from any contracts entered into by You and Us;
• perform the Services You’ve requested. For example, if You fill out a “Contact Request” web form, We will use the information provided to contact You about Your interest in the Services;
• seek Your views or comments on the Services we provide, through surveys We may send You;
• notify You of changes to our Services;
• send You communications which You have requested and that may be of interest to You;
• plan and host corporate events, host online forums and social networks in which You choose to attend and/or participate;
• plan activities, events, promotions related to our Services;
• provide you with access to Apps with information of events we host;
• process a grant or job application;
• contact You to further discuss Your interest in the Services and to send You information regarding CIGNON and its partners, such as information about CIGNON products and information on application development and digital transformation.

Who has access to Your information?

We may share Your information with other companies in order to work with them, including subsidiaries and affiliates of CIGNON corporate group. For example, CIGNON may need to share your information with other companies within the CIGNON corporate family for customer support, marketing, technical operations, and account management purposes.

We may pass your information to our third-party service providers such as CIGNON Partners, for the purposes of completing tasks and providing Services to You on Our behalf (for example to provide you with a demo of CIGNON, to provide You training on CIGNON, to develop software applications on CIGNON). However, when we use third-party service providers, we disclose only the personal information that is necessary to deliver the Service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes unless you have provided Your consent or requested Us to do so, or We are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

CIGNON does not share Your collected information with business partners, unless: (1) You specifically opt-in to such sharing via an event registration form; or (2) You attend an CIGNON event and allow CIGNON or any of its business partners to scan your attendee badge. If You do not wish for Your information to be shared in this manner, You may choose not to opt-in via event registration forms and elect not to have Your badge scanned at CIGNON events. If You choose to share Your information with business partners in the manners described above, Your information will be subject to the business partners’ respective privacy statements.

CIGNON will disclose personal information where required by law or legal process, for the administration of justice, to protect your vital interest, for investigations by law enforcement or regulatory bodies, to protect and defend CIGNON property and legal rights, to protect the personal safety of CIGNON website or (mobile) app users, or by order of a valid injunction from a court or law enforcement agency.

Unless described in this Statement, CIGNON does not share, sell, rent, or trade any information with third parties for their promotional purposes.

CIGNON posts a list of customers and testimonials on CIGNON website that shows information such as customer names and titles. CIGNON obtains the consent of each customer prior to posting any information on such a list or posting testimonials.

Security precautions in place to protect the loss, misuse or alteration of your information

At CIGNON, We believe You have a right to understand how we protect your applications and data.

We use appropriate technical, organizational and administrative security measures to protect the data supplied by You and managed by Us against loss, misuse, unauthorized access, disclosure, alteration, and destruction. Our security measures are continually improved in line with technological developments. For instance, CIGNON works with compliance procedures and our partners certifications with ISO 27001, ISO 22301 and SOC 2 Type II standards provides reasonable assurance of Our security and business continuity practices.

Even considering CIGNON security endeavours, Our users also play an important role regarding the security of their personal data. The security measures applied on Your assets or the assets of Your company, as well as Your behaviors when using these assets are crucial for maintaining personal data secure. Actions such as defining a weak password to access Our services, not locking Your laptop or mobile device when You left it unattended, or using public assets to login on Our website, all pose a risk. This way, we ask You to take all the necessary precautions in order to avoid security breaches.

Use of Cookies

Like many other websites, CIGNON website uses cookies. If you decide to change your consent preferences , please be aware that you should clean your browser cookies to remove previously installed cookies.

Please bear in mind that turning cookies off may result in a loss of functionality when using our website.

List of cookies

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts.

16 or Under

We are 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.

Transferring your information

We are a global group of companies and We have databases in different countries, some of which are operated by the local CIGNON company, and some of which are operated by third parties on behalf of the local CIGNON company. We may transfer Your data to one of the CIGNON databases outside Your country of domicile, potentially including countries which may not require an adequate level of protection for your personal data compared with that provided in your country. For instance, if You use our Services while you are outside the European Union (EU) region, your information may be transferred outside the EU in order to provide you with those Services.

We ensure there are adequate safeguards in place when transferring Your data outside Your country and the EU, including by relying on Model Clauses, or other lawful mechanisms or otherwise that the transfer only occurs where permitted by applicable law, with the aim of ensuring that your privacy rights continue to be protected as outlined in this Statement

Website recording

We use third-party and CIGNON own technology to improve our website and product experience and usability. It collects information such as mouse clicks, mouse movements, page scrolling, and any text keyed into website forms, for aggregated and statistical reporting. This service is only on the CIGNON website and for internal use only. We anonymize your personal data to the extent possible; however, for technical reasons, we cannot assure full anonymization. We process your personal data under our legitimate interest in improving our service, under art. 6, par. 1, lit f), GDPR. You can contact us and object to such processing.

Data Retention

We will keep your personal information for two years from your last interaction with us, such as the date your account was deleted, your last order, the last time you used one of our apps, or in some other way contacted or interacted, unless a longer or shorter retention period is required by law, is necessary in the course of legal proceedings, or is otherwise needed for a particular purpose under applicable law.

For the purposes of provide you with access to Apps in order to obtain information of our events, we will retain your data up to 3 months after the App is disabled.

The following are examples of how CIGNON might keep your personal information for as long as necessary for a particular purpose:

1. We may keep your personal information collected during a purchase of a Service for as long as required by tax laws (longer than two years in some European countries);
2. We may keep your personal information for a shorter period if you ask us to delete your personal information. In such a case, CIGNON will aim to delete your personal information within a maximum period of one month from the date of the request.

In general, We will hold Your personal information on Our systems for as long as is necessary for the relevant Service, or as long as is set out in any relevant contract You hold with Us and for a reasonable period of time afterward, for instance to pursue Our legitimate business interests, conduct audits, comply with Our legal obligations, resolve disputes, and enforce our agreements.

We review our retention periods for personal information on a regular basis.

How you can access and update your information

If you have registered for an account with CIGNON, you may generally update your user settings, profile and, organization’s settings by logging into the CIGNON website or into the applicable Service with your username and password and editing your settings or profile. To update your information, discontinue your account, and/or request return or deletion of Your data associated with your account, please contact dpo@CIGNON.com. For other requests to access, correct, modify or delete Your personal information, please contact dpo@CIGNON.com.

We will respond to your requests without undue delay, but within one month. If permitted under applicable legislation, CIGNON may extend the response period with two further months if such is necessary due to the complexity and number of requests. CIGNON will notify you of any extension and the reason thereof. If CIGNON denies Your request, We shall inform You on the reasons for such a denial.

If information about You is processed by CIGNON on behalf of one of our customers, We will forward Your request to the relevant customer. We will inform You that We have forwarded your request and provide You with the contact details of the relevant client.

OPTING OUT AND UNSUBSCRIBING FROM MARKETING MESSAGES

All of our marketing communications contain an easy way to opt out from receiving future messages, such as a link through which you can unsubscribe. If you would like to opt out of receiving CIGNON marketing messages you may use the unsubscribe link contained in the messages you have received, or alternatively you can contact our
Data Protection Officer by E-mail at: dpo@CIGNON.com

Note that if you choose to opt out of receiving marketing messages in the manner explained above, we will continue to process your personal information, in particular to allow us to understand your interests and preferences, but we will stop using your personal information to send you personalized or non-personalized marketing messages. If you would like us to stop such processing in part or in full, we have explained how to do this in the above paragraph.