Privacy Policy

Sistemma International Ltd. respects your privacy as a visitor to our Site. It is important for you to understand what information we collect about you during your visit and what we do with that information. Your visit to this Site is subject to this “Privacy Policy” and our Terms of Use.

Sistemma International Ltd. will not use information provided through your use of this Site except as set forth in this Privacy Policy.

Like many other web sites, we actively collect information from our visitors both by asking specific questions on this site and by permitting you to communicate directly with us via e-mail. Some of the information that you submit may be personally identifiable (that is, information that can be uniquely identified with you, such as your name, address, e-mail address, phone number, etc.). We use this information to send you further information regarding Sistemma International Ltd.

This website uses cookies to improve site functionality, provide you with a better browsing experience, and serve more relevant content to you. These cookies collect information on your interactions with our site including the pages you visit, the links you click on and how long you are on our site. This website also uses cookies to help us deliver more targeted ads and assess the performance of ad campaigns.

Sistemma International Ltd. may collect, store or accumulate data about your usage of this website. This data may be shared or transferred to third parties, as defined in the Third Parties section of our Privacy Policy. Some cookies used on this site are from Third Parties. These Third Party cookies are used to provide us with analytics and intelligence about usage of our site.

If you do not want Cookies to be dropped on your device, you can adjust the setting of your Internet browser to reject the setting of all or some Cookies and to alert you when a Cookie is placed on your device. For further information about how to do so, please refer to your browser “help” / “tool” or “edit” section or see www.allaboutcookies.org. Please note that if you use your browser settings to block all Cookies (including strictly necessary Cookies), you may not be able to access or use all or parts or functionalities of our Sites.

If you want to remove previously-stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Sites from placing further Cookies on your device unless and until you adjust your Internet browser setting as described above.

For more information on the development of user-profiles and the use of targeting/advertising Cookies, please see www.youronlinechoices.eu if you are located in Europe or www.aboutads.info/choices if in the United States.

Sistemma International Ltd. uses your personal information to enhance the operation of this site, allow you to use all of its features and respond to your requests for information. Sistemma International Ltd. may contact you about new features or services in which it believes you may be interested.

We may disclose any information we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request.

Personal Data is processed in the European Union. If you are located outside the EU and choose to provide information to us, Sistemma International Ltd. transfers Personal Data to the EU and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Sistemma International Ltd. shall process Personal Data from our Users who reside in the European Union in accordance with the requirements of the GDPR.

European Union General Data Protection Regulation 2016/679

European Union General Data Protection Regulation EU 2016/679 (“GDPR”), approved by the European Parliament on April 14, 2016, and effective May 25, 2018, addresses the protection of natural persons located in the EU with respect to the processing of their Personal Data.

GDPR recognizes that Personal Data shall be:

Processed lawfully, fairly and in a transparent manner

Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes

Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed

Accurate and, where necessary, kept up to date

Kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the personal data are processed

Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures

As a Controller, Sistemma International Ltd. shall be responsible for, and shall be able to demonstrate compliance with, the foregoing principles. Therefore, you have the right:

To request the correction or update of any Personal Data that is incorrect or incomplete

To request the erasure of your Personal Data (the right to be forgotten)

To portability of your Personal Data

To object to the processing of your Personal Data

Not to be subject to a decision based on automated decision-making, including profiling

To withdraw consent to the processing of your Personal Data

To register a complaint with a supervisory authority (if you are located in the EU)

Unless otherwise prohibited by law, Sistemma International Ltd. will effect any such request without delay. Where Sistemma International Ltd. is able to comply with a request for erasure by anonymizing the Personal Data, we will do so.

Under the GDPR, you have the right to be forgotten. If you reside in an EU territory, you may request the deletion of your personal data that we collect, store, or process. When you make your request, we will balance the privacy rights of the individual concerned with the interest of the general public in having access to the information, as well as the right of others to distribute the information. For instance, we may refuse to delete information regarding financial scams or other unlawful activities. In the event Sistemma International Ltd. receives a request for erasure, or a request to be forgotten, Sistemma International Ltd. has the obligation to erase the Personal Data without undue delay (and no longer than thirty (30) days after the request is received), where one of the following grounds applies:

The Personal Data is no longer necessary for the purpose for which it was originally collected or processed

You withdraw your consent to the collection or processing of your Personal Data.

You object to the processing and there is no overriding legitimate interest for continued collection or processing of your personal data

You believe that your Personal Data was unlawfully processed or collected (i.e., in breach of the GDPR)

Your Personal Data must be erased in order to comply with an EU or an EU Member State law to which we are subject

Such Personal Data was processed in relation to the offer of information society services to a child

If you would like to submit a request for erasure (request to be forgotten), please use the form linked here.

Sistemma International Ltd. as Data Controller / Privacy Officer

For Users in the EU, Sistemma International Ltd. is a Controller, as defined in the GDPR, of your Personal Data. Should you have questions or requests regarding your Personal Data, you may contact Sistemma International Ltd. at any time at [email protected].

We may use IP addresses to analyze usage, administer our Site, and gather demographic information for aggregate use.

Third Parties

Some cookies we use on our site are from third party companies, Google Analytics and HubSpot, to provide us with web analytics and intelligence about our site. Cookies allow us to improve site functionality, provide you with a better browsing experience, and serve more relevant content to you. These cookies collect information on your interactions with our site including the pages you visit, the links you click on and how long you are on our site. This website also uses cookies to help us deliver more targeted ads and assess the performance of ad campaigns. We partner with a marketing agency, Brafton, to whom we may share this web analytics data from time to time. We share this data in order to improve our website and marketing efforts.

Of the third party companies listed, HubSpot is the only third party company that tracks identifiable information by recording your IP address when you visit our website. HubSpot tracks this information to log separate website interactions with one visitor. By tracking this information, we can better understand how one individual interacts with our website and the director of the website traffic. This enables us to provide you with a better browsing experience, and serve more relevant content to you.

Choices You Have About How Sistemma International Ltd. Uses Your Information

We strive to provide you with as many choices and as much control as possible regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

You may send us an e-mail message at [email protected] to request access to, correct or delete any personal information that you have provided to us.

You may also opt out of receiving marketing messages from Sistemma International Ltd. by notifying us at [email protected].

You should review this privacy policy carefully, because if you do not agree with our practices, your ultimate choice is not to use this site. Remember, by using any part of this site, you accept and agree to our privacy practices. If we update this privacy policy, your continued use of this site (following the posting of the revised policy) means that you accept and agree to the terms of the revised privacy policy.

How Sistemma International Ltd. Protects Your Information

Sensitive Data

Our website does not intentionally collect, process, transfer, or store Sensitive Data, which is defined in the GDPR as data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data that concerns health, or data that concerns a natural person’s sex life or sexual orientation.

Access to and Accuracy of Your Personal Data

Sistemma International Ltd. strives to keep your Personal Data accurately recorded. You have the right to access and request the correction, amendment, or deletion of all of your recorded Personal Data that has been collected by us. If you wish to review your recorded Personal Data, please contact us at [email protected]. Please include your name, email address, and telephone number and let us know what kind of information you want to see. You may see and copy your information in person, or if you prefer, we will copy and send you your information. If you see any mistakes, let us know and we will review them. If we agree, we will correct our files. If we disagree, you may file a short statement of dispute with us. Your statement will be included with any data we disclose in the future. We will also send the statement to anyone you ask us to who received your information from us in the past two years.

Data Retention

Sistemma International Ltd. retains Personal Data for as long as we reasonably require it for legal or business purposes. In determining data retention periods, Sistemma International Ltd. takes into consideration local laws, contractual obligations, and the expectations and requirements of our Users. We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. When we no longer need Personal Data, we securely delete or destroy it.

Links

This Site may contain links to or from other websites. Please be aware that we are not responsible for the privacy practices of other websites. This Privacy Policy applies only to the information we collect on this Site. We encourage you to read the privacy policies of other websites you link to from our Site or otherwise visit.

Notification of Changes

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised policy here. As we may make changes at any time without notifying you, we suggest that you periodically consult this Privacy Policy. Please note that our rights to use any information collected will be based on the privacy policy in effect at the time the information is used.

What Sistemma International Ltd. Does About Children Visiting This Web Site

This Web Site is not intended for children under the age of 13. We will not knowingly collect information from Web Site visitors in this age group. We encourage parents to talk to their children about their use of the Internet and the information they disclose online.

Comments

We have taken great measures to ensure that your visit to our Site is a satisfying one and that your privacy is constantly respected. If you have any questions, comments or concerns about our privacy practices, please contact us via e-mail at [email protected].