GilCat Solutions offers a wide range of solutions that involved many different products, from products used to help operate enterprises, to serve you better and host solutions for complex problems. References to GilCat Solutions products in this statement include GilCat services, websites, apps, software, servers and devices.
Please read the product-specific details in this privacy statement, which provide additional information about some of GilCat products. This statement applies to GilCat interactions with you and the GilCat products listed below, as well as other GilCat products that display this statement.
GilCats (‘we’ or ‘us’ or ‘our’) is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the FTC Act.
GilCats is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
GilCats already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018. Our preparation includes: –
Policies & Procedures – continuously revise data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –
Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
International Data Transfers & Third-Party Disclosures – where GilCats stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
Legal Basis for Processing – we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
Obtaining Consent – we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
Direct Marketing – we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
Processor Agreements – where we use any third-party to process personal information on our behalf (e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
Special Categories Data – where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website, in the office, during induction of an individual’s right to access any personal information that GilCats processes about them and to request information about:
Personal Data We Collect
GilCat Solutions collects data to operate effectively and provide you the best experiences with our products. You provide some of this data directly, such as when you create a GilCat Solutions account, register for a GilCat Solutions event, purchase a subscription, sign up for services, or contact us for support. We get some of it by recording how you interact with our products by, for example, using technologies like f We also obtain data from third parties.
How We Use Personal Data
We are the sole owners of the information collected on this site. GilCat Solutions uses the data we collect to operate our business and provide you the products we offer, which includes using data to improve our products and personalize your experiences. We also may use the data to communicate with you, for example, informing you about your account, security updates and product information.
We Never Share Personal Data
We never share your data without your consent unless necessary to complete any transaction or provide any product you have requested or authorized.; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of our products; and to protect the rights or property of GilCat Solutions.
How to Access & Control Your Personal Data
You can view, edit, or delete your personal data online for many GilCat Solutions products. How you can access or control your personal data will depend on which products you use. You can always choose whether you wish to receive promotional email, SMS messages, telephone calls and postal mail from GilCat Solutions. You can also opt out from receiving communications from GilCat Solutions by visiting our opt-out page.
Cookies & Similar Technologies
You have a variety of tools to control cookies, web beacons and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons and similar technologies. Your browser and other choices may impact your experiences with our products.
Notice to End Users
Many GilCat Solutions products are intended for use by organizations and are administered to you by your organization. Your use of GilCat Solutions products may be subject to your organization’s policies, if any. If your organization is administering your use of the GilCat Solutions products, please direct your privacy inquiries to your administrator.
If you use an email address provided by an organization you are affiliated with, such as an employer or school, to access GilCat Solutions online services, the owner of the domain (e.g., your employer) associated with your email address may: (i) control and administer your GilCat Solutions online services account and (ii) access and process your data, including the contents of your communications and files.
In the event of a conflict between this GilCat Solutions privacy statement and the terms of any agreement(s) between a customer and GilCat Solutions for Enterprise and Products, the terms of those agreement(s) will control.
You can also learn more about our Services and Products’ features and settings, including choices that impact your privacy or your end users’ privacy, in product documentation.
If any of the terms below are not defined in this Privacy Statement, they have the definitions below.
When a customer tries, purchases, uses, or subscribes to Enterprise and Developer Products, or obtains support or professional services with for such products, GilCat Solutions collects data to provide the service, including uses compatible with providing the service, provide the best experiences with our products, operate our business, and communicate with the customer. For example:
When a customer engages with a GilCat Solutions sales representative, we collect the customer’s name and contact data, along with information about the customer’s organization, to support that engagement.
When a customer interacts with a GilCat Solutions support professional, we collect more information like for example device, error reports to diagnose and resolve problems.
When a customer pays for products, we collect contact and payment data to process the payment.
When a customer receives communications from GilCat Solutions, we use data to personalize the content of the communication.
When a customer engages with GilCat Solutions for professional services, we collect the name and contact data of the customer’s designated point of contact and use information provided by the customer to perform the services that the customer has requested.
Our Security and Access Control Products enable you to purchase, subscribe to or use other products and online services from GilCat Solutions or third parties with different privacy practices, and those other products and online services will be governed by their respective privacy statements and policies.
Technical Support Products
Technical Support products are applications, software and services we use to provide you with troubleshooting and fulfil our mission based on the product and services purchase. Which includes improving and personalizing your experiences.
Information Security & Technical and Organisational Measures
GilCats takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including:
We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline. Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the address of the Web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.
In order to use this website, a user must first complete the registration form. During registration a user is required to give certain information (such as name and email address). This information is used to contact you about the products/services on our site in which you have expressed interest. At your option, you may also provide demographic information (such as gender or age) about yourself, but it is not required.
We request information from you on our order form. To buy from us, you must provide contact information (like name and shipping address) and financial information (like credit card number, expiration date). This information is used for billing purposes and to fill your orders. If we have trouble processing an order, we’ll use this information to contact you.
We use an outside shipping company to ship orders, and a credit card processing company to bill users for goods and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes beyond filling your order.
We use “cookies” on this site. A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site.
This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
Surveys & Contests
From time-to-time our site requests information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.
GDPR Roles and Employees
GilCats have designated Christopher Tryon as our Data Protection Officer (DPO) to develop and implement our roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
GilCats understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our preparation for the GDPR, please contact Christopher Tryon at firstname.lastname@example.org