PRIVACY AND DATA PROTECTION AT GRADIENTM
This policy has been updated on December 11, 2019, to reflect GRADIENTM’s commitment (1) for international data transfers as related to the potential withdrawal of the United Kingdom (UK) from the EU (“Brexit”) and (2) to GRADIENTM’s obligations as a service provider related to the California Consumer Privacy Act.
At GRADIENTM our commitment to privacy goes beyond the minimum legal and regulatory requirements. We strive for best-in-class data protection and privacy management, which requires a sound data privacy governance structure and an effective data privacy compliance and best practices program to ensure GRADIENTM meets ever-changing and increasingly-complex regulatory standards and all contractually agreed privacy obligations.
GRADIENTM’s Global Privacy and Data Protection Office has strategic and operational responsibility for this program, which is adequately resourced and appropriately organized to ensure the policies and compliance processes, technology and physical controls and security we rely upon to govern the collection, use, storage and transfer of personal data all over the world meets statutory and regulatory requirements. Therefore, GRADIENTM’s approach is to coordinate the contribution of several corporate disciplines – including ethics and compliance, legal, human resources, and information and physical security – to achieve our “best in class” data protection and privacy management objectives.
GRADIENTM has implemented technology, management processes and policies aimed to maintain data accuracy. According to applicable laws, GRADIENTM provides individuals with reasonable access to personal information that they provided to GRADIENTM and the reasonable ability to review and correct the data or ask for anonymization, blockage, or deletion, as applicable. To protect your privacy and security when submitting an access request, we will take reasonable steps to verify your identity, such as requiring a password and user ID, passport number and/or other unique personal identifiers before granting access to your data. To submit your access request, please contact the GRADIENTM Global Privacy and Data Protection Office at privacy@GradientM.com .
NOTIFICATION OF CHANGES
We will post a notice for 30 days at the top of this page notifying users when this Privacy Statement is updated or modified in a material way. If we are going to use your personal information in a manner different from that stated at the time of collection, we will notify you, and you will have, subject to legal and/or contractual provisions, a choice as to whether or not we can use your personal information in such a way.