Aduro Consulting, LLC, (” Aduro”) a limited liability company with its principal place of business at 355 Metropolitan Ave, Boston, MA 02131 processes Personal Data (as defined below) in the course of its business, including the Personal Data of people browsing the website of Aduro (the “Site”).
Personal data (“Personal Data”) means any information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the person.
Non-Personal Data means any information that does not result in the identification of a person.
- DATA COLLECTED
Visitors are individuals who visit the Site without registering themselves. Their Personal Data likely includes:
IP and/or MAC address
Cookies (as described below); and any other Personal Data as may be relevant for the purposes listed below.
Personal Data collected (including from those who visit Site and enter information) for the purposes listed below likely includes:
first and last name;
login and password;
university, degree and courses taken;
type of organization (company, school, university, etc.), organization name, organization size, department and job title;
industry and industry sub-industry sectors;
people to whom purchases are shipped;
financial data (credit card number and expiry date, name and address of the cardholder);
IP and/or MAC address;
Cookies (as described in section 10); and
any other Personal Data as may be relevant for the purposes listed below.
In all cases, however, the Personal Data gathered is limited to data necessary for the purposes described in Article 4 below.
For visitors and users of the Site: in order to use certain functions and features of the Sites, Aduro requires that You provide certain Personal Data when visiting or using the Sites. You are free to decide whether or not to provide all or part of Your Personal Data. However, if You choose not to provide all or part of this Personal Data, the purposes as described in Article 4 hereafter might not be achieved or not properly achieved, some areas and functions of the Site may not function properly and/or You may be refused access to certain pages on the Sites. In particular, You will not be authorized to purchase software licenses or other products or services via the Sites.
- PURPOSES AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
Whether You are a visitor or a user, Aduro collects Your Personal Data for the following legal grounds and for the following purposes:
- Processing activities based on Your consent:
To improve Your user experience;
To recognize that You have given Personal Data so You don’t need to do it for every web page requested;
- Processing activities based on Aduro’s legitimate interest:
In addition, when You are a user, Aduro collects Your Personal Data on the following legal grounds and for the following purposes:
- Processing activities based on Your prior consent:
To enable You to request and receive information on Aduro and Aduro services from Aduro;
To ascertain Your requirements and interests and provide You with the most suitable services;
To enable Aduro to manage its marketing;
To enable You to register for a seminar, webinar, or event;
Aduro may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram, or Google) where this information is matched against the social networks’ data own data bases in order to display to You more relevant information.
- Processing based on Aduro’s legitimate interest:
To enable Aduro to manage its marketing activities for other services if You are already using Aduro products and services;
To manage the Aduro obligations related to applicable export laws, trade sanctions, and embargoes issued, without limitation, by the European Union and its member states, and of the United States of America. This may include (i) automated checks of any user registration data as set out herein and other information You provide about Your identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when You update Your information; (iii) blocking of access to Aduro services and systems in case of a potential match; and (iv) contacting You to confirm Your identity in case of a potential match;
Generally, when consent is not required, You cannot opt out of non-marketing related communications that are required for the relevant business relationship. With regard to marketing-related communications (e.g., emails and phone calls), Aduro will (i) where legally required, only send You such communications after You have opted in, and (ii) provide You the opportunity to opt out of receiving further marketing-related communications from Aduro.
When You register for an event organized by Aduro, Aduro may share Your name, company, and email address with other participants and sponsors of the same event for the purpose of communication and the exchange of ideas. In addition, Aduro may ask You for information about Your health for the sole purpose of identifying and being considerate of individuals who have disabilities or special dietary requirements throughout the event.
Subject to applicable local law, by providing Personal Data such as but not limited to e-mail address, You hereby expressly authorize Aduro to use it together with other relevant Personal Data to send You commercial or marketing communications. Aduro might also use Your email address for administrative or other non-marketing purposes (for example, to notify You of significant changes to the Site).
- PERSONAL DATA RETENTION PERIOD
Aduro does not store Your Personal Data for more time than necessary. Retention periods may vary depending on the data categories and the processing activities.
Where Aduro is processing and using Your Personal Data as permitted by law or under Your consent, Aduro will store Your Personal Data (i) only as long as required to fulfill the purposes set out above, (ii) where Aduro has a legitimate interest in using Your Personal Data, until You object to Aduro’s use of Your Personal Data, or (iii) where You gave Your consent, until You withdraw it. However, where Aduro is required by applicable law to retain Your Personal Data longer or where Your Personal Data is required to assert or defend against legal claims, Aduro will retain Your Personal Data until the end of the relevant retention period or until the claims in question have been settled.
- RIGHT TO ACCESS, TO RECTIFICATION AND OTHER RIGHTS
You have a right to access Your Personal Data. In addition, You have a right to request the rectification, completion, update or erasure of Your Personal Data. You have a right to restrict processing. You also have a right to obtain a copy of Your Personal Data stored by Aduro. You have a right to object, in relation to specific processing of Your Personal Data. Additionally, You may have a right to data portability.
You may exercise Your rights by sending an email to email@example.com.
Depending on the scope of the request, Aduro reserves the right to charge a reasonable fee to cover any out-of-pocket costs incurred in connection with such access, modification and deletion of Personal Data. Aduro may deny access to Personal Data in limited circumstances, defined by applicable laws and regulations.
- DATA RECIPIENTS
Aduro may disclose Your Personal Data if required by law or if Aduro believes in good faith that such disclosure is reasonably necessary to comply with legal process (for example, a warrant, a subpoena, or other court order) or protect the rights, property, or personal safety of Aduro, Aduro’s customers, or the public.
If allowed by applicable law, Aduro may also share Your Personal Data with third parties in order to offer You targeted marketing or advertising.
- DATA SECURITY
Aduro undertakes to ensure the protection and security of Personal Data that You choose to communicate, in order to ensure the confidentiality of Your Personal Data and prevent Your Personal Data from being distorted, damaged, destroyed or disclosed to unauthorized parties.
Aduro maintains reasonable physical, electronic, and procedural safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. As part of those safeguards, Aduro employs sophisticated technology designed to protect Personal Data during its transmission and prevent transmission errors or unauthorized acts of third parties. However, while Aduro strives to protect Your Personal Data, in light of the inevitable risks of data transmission over the internet, Aduro cannot guarantee full protection against any error occurring during the course of Personal Data transmission which is beyond Aduro’ reasonable control.
Since all Personal Data is confidential, access is limited to employees, contractors and agents of Aduro or Aduro Group Companies who have a need to know such data in carrying out their tasks. All the people who have access to Your Personal Data are bound by a duty of confidentiality and subject to disciplinary actions and/or other sanctions if they fail to meet these obligations.
However, it is important for You to exercise caution to prevent unauthorized access to Your Personal Data. You are responsible for the confidentiality of Your password and information appearing on Your account. Consequently, You must ensure that You log out of Your session in the event of shared use of a computer.
- LINKS TO WEBSITES NOT CONTROLLED BY ADURO
The Site might offer links to third party websites which may be of interest to You.
Aduro does not exercise any control over the content of third party websites or the practices of these third parties in connection with the protection of Personal Data that they might collect and are thus not in the control of Aduro. Consequently, Aduro shall have no liability for the content of third party websites or the practices of these third parties concerning the protection of Personal Data.
It is therefore Your responsibility to inform yourself of the privacy policies of these third party websites.
- DISPUTE RESOLUTION
Although Aduro has put in place reasonable safeguards to protect Personal Data, Aduro recognizes that there is no method of transmitting or storing Personal Data that is completely secure.
However, Aduro is committed to ensure the privacy of Personal Data: if You have a reason to believe that the security of Your Personal Data has been compromised or misused, You should contact Aduro via the following address: firstname.lastname@example.org
Unauthorized access to Personal Data or the improper use of Personal Data may constitute offenses under local law.
If Your usual place of residence is in European Union, Lichtenstein, Norway or Iceland, You have a right to file a complaint with Your competent data protection authority.