Privacy Policy
This policy is provided on behalf of Gala Export LLC and
explains the processing of your personal data by Gala Export It sets out how the personal data
that we collect from you, or that you provide to us, will be processed by us.
The data controller for this policy is Gala Export Our
contact information can be found at the end of this policy.
The personal data of individuals discussed in this policy is
primarily collected because Gala Export is in, or is seeking to enter in, a
commercial relationship with the entities you are employed by.
The collected information and its use varies based on
whether we have a pre-existing, commercial relationship between Gala Export and
your employer (see section for CUSTOMERS AND PARTNERS) or we have no prior
engagement with your employer (see section about MARKETING).
Marketing
What kind of data we collect on you
From persons visiting our
website, we acquire data on the device used, your IP address, the route by
which you arrived at our website, and your activities therein, as well as any
information you have submitted to us through forms.
If you provide us your data via
forms – online or offline – we ask you the following information: names of the
person and company, email address, country, industry, size of company,
telephone number, and area or service of interest.
We may also collect your
information via our discussion boards or other social media hosted by Gala
Export, competitions, promotion, surveys, webinars, and other such events or
points of interaction.
If you have been identified as a
decision maker or influencer by a third party, or listed as such in public
sources, we typically obtain the following information on you and the
organization that you represent: company name, title, name, function, language,
email, zip code, city and state, country, phone number, industry, turnover, and
size of company.
We may aggregate such data with
general data on your organization.
For what purposes do we use it
We collect and process the data
so that we can, based on your position in your organization, send you
information relating to the services, conduct customer surveys, arrange
competitions, advertise and market our services (both personalized and in
aggregate), and share information and know-how about cyber security and on our
services. We also make use of the collected data in market research, product
and service development, and business offering development.
Should you or the organization
that you represent become our customer, we combine data collected at this
pre-sales phase for you when your organization becomes our customer. In such
cases, we use it in accordance to the same practices that we employ with the
representatives of our corporate customers and partners.
Legal Grounds
We collect data on individuals in
influential, decision-making positions in companies that would benefit from our
services. We consider such activity to be in the legitimate interests of both
Gala Export as a vendor and your employer as a buyer.
Where legitimate interest is not
suitable or applicable to a type of data processing, we will seek your consent.
For example; consent is the legal grounds for data that we collect on your
browsing of our websites. Where we base our processing on consent, you may
Customers and Partners
What kind of data we collect on you
Regarding individuals, with whose
employers we are in a commercial relationship, we process the following
personal data on you: your name, your position / role / title, your email
address and phone number, which legal entity that has purchased the license or
service, such entity’s street / mailing address, country, your language and
messaging preferences, available LinkedIn information, relevant access
credentials to and logs in our systems.
Gala Export collects this data:
Via marketing activities (more information under Corporate
Business - marketing),
Via our website, our discussion boards or other social media
hosted by Gala Export,
Via competitions, promotion, surveys, webinars, and other
such events or points of interaction,
Through sales, support, and account management activities,
and
Through partner sales and customer management activities
(e.g. a partner orders a license to an end customer or changes an end
customer’s information).
For what purposes do we use it
We collect and process the data
so that we can manage our customer relationships, provide you with information,
products and services that you request from us, run joint planning sessions,
analyze the data for business development purposes, deliver license
certificates, undertake all steps of order fulfillment and payment processes,
perform personalized marketing activities, communicate in relation to both the
initial sales of our services as well as license and service renewals, our
other offerings and other relevant information, collect your feedback and
identify authorized users for selected systems and administer user accounts,
and provide help and support for the services.
As you may approach us or submit
information to us via multiple channels – such as our resellers, events, or
website – we combine such information to make our communications relevant to
your needs.
Legal Grounds
Gala Export has a legitimate
interest to process personal data of the employees of its customers and
partners to enable and facilitate provisioning its commercial services to its
corporate customers and partners, including undertaking relevant sales and marketing
activities as enabled by applicable laws on different forms of
marketing-related communications.
Where processing is required for
an activity, it is necessary that we are able to process the required data.
This is the case e.g. when we need to effectively communicate with the
representatives of our partners and customers, deliver and invoice the agreed
services, respond to an enquiry or support request, or enable your
participation in our corporate customer beta program.
Where legitimate interest is not
suitable or applicable to a type of data processing, we will seek your consent.
For example; consent is the legal grounds for data that we collect on your
browsing of our websites. Where we base our processing on consent, you may
withdraw your consent at any time.
Third parties
We also work closely with third parties (including, for
example, business partners, subcontractors in technical, payment, and delivery
services, advertising networks, analytics providers, search information
providers, credit reference agencies) and may receive information about you
from them. These vendors have collected this information from private or public
sources or directly from you.
Other uses and disclosures
Information on secondary purposes for which personal data
may occasionally be processed.
There are circumstances not
covered by this privacy policy where the use or disclosure of personal data may
be justified or permitted, or where we may be obligated by applicable laws to
disclose information without acquiring your consent or independent of service
provisioning.
One example includes complying
with a court order or a warrant issued by the authorities in the relevant
jurisdiction to compel the production of information.
Similarly, there may be other
circumstances where there is a justifiable legitimate interest to disclose
limited sets of information to a third party. Examples of such disclosures
include cases where we need to protect ourselves against liability or to prevent
fraudulent activity, where it is necessary to solve or contain an ongoing
problem, or where we need to meet the legitimate information requirements of
our insurers or governmental regulatory agencies. In any such action, we will
act according to the applicable laws.
We may also need to transfer your
personal data as part of a corporate transaction, such as a sale, merger,
spin-off, or other corporate reorganization of Gala Export, where the
information is provided to the new controlling entity in the regular course of
business. Gala Export discloses and transfers data internally as required by
our then current operational model. We do, however, limit the disclosures
internally to only those group companies, units, teams, and individuals who
have a need to know such information for the intended purposes of processing
it.
We weigh each disclosure
requirement carefully and take the possibility of such disclosure requests into
account when deciding where and how we store your personal data.
Retention
On a monthly basis, we purge our
direct marketing records from all contacts who have not reacted to our
messaging or visited our web pages during the last 24 months and who are not
affiliated with any of our customers or partners.
If you become our customer or
partner, the data is retained for the duration of your organization's relation.
User data in our corporate customer registry is stored for the duration of the
license/subscription/engagement and up to five years after the last engagement
or subscription with the customer or partner has expired.
Security
Information on the security practices that we employ to keep
your data secure.
We apply strict security measures
to protect the confidentiality, integrity, and availability of your personal
data when transferring, storing, or processing it.
We use physical, administrative,
and technical security measures to reduce the risk of loss, misuse, or
unauthorized access, disclosure, or modification of your personal data.
All personal data is stored on
secure servers operated by Gala Export or our partners with access limited to
authorized personnel only.
Contact information
If you have any questions or
concerns about the matters discussed in our privacy policies, please contact:
Email: info@galaexport.com
General
Information on definitions and change management.
Definitions
This is what we mean when we make certain references within
this policy.
“Client”, “you”, refers to any
data subjects who buy, register for use, or use our services, whose devices and
data traffic are protected by our services, or who may have submitted
personally identifiable information to us. This information may have been
submitted through the use of our services, websites, telephone, email,
registration forms, or other similar channels.
“Personal data” refers to any
information on private individuals that is identifiable to them or their family
or household members. This information may include names, email and mailing
addresses, telephone numbers, billing and account information, and other, more
technical information that can be linked to you, your device, or the behavior
of either, that we process while providing our services.
“Services” refer to any services
or products that are manufactured or distributed by Gala Export, including
software, web solutions, tools, and related support services.
“Website” refers to the
www.GalaExport.com website or any other website that Gala Export hosts or
controls, including subsites and browser-based service portals.
Changes
This version of the policy
clarifies, updates, and replaces the previous version. To continue keeping this
document up to date, we will make changes and additions to this from time to
time also in the future.
We will publish the changed
policy document on our website or at another interaction point where it has
previously been made available. If the changes are significant, we may also
notify you by other means. Any changes will apply starting from the date that
we publish the revised policy document.