Sourcengine
Sourcengine

Privacy Policy

Sourceability SG Pte. Ltd., a company incorporated in Singapore, and Sourceability North AmericaLLC, a company incorporated in the USA (collectively "Sourceability") own and operate the Sourcengine website (the "Website"). Sourceability has implemented this privacy policy ("Policy") to properly handle the Personal Data (as defined below) provided to or obtained by Sourceability through the Website. Sourceability may modify the Policy to reflect changes in applicable law or for any other reasons deemed necessary by Sourceability. Any modifications to the Policy shall apply immediately upon such modified Policy being posted on the Website.

By accepting the Policy when registering for an account on our Website (the "Account") in order to use the services provided through the Website (the "Services"), or when providing Personal Data otherwise by using the Website, you expressly consent to our collection, storage, use and disclosure of your Personal Data as described in this Policy.

For the purposes of this Policy, the term "you" and "your" shall include (i) the representative(s) of the company who are authorized to access the Website and use the Services and (ii) the company itself.

1 Privacy Notice

Sourceability respects your privacy. For our business, Sourceability will collect, store and use your Personal Data for defined purposes. Sourceability uses your Personal Data to support and enhance our relationship with you, for example, to enable the sale of your products, to process your purchases, to contact you to resolve any issues, to provide service and support, and share information with you.

If you use the Website in the European Union (EU) or another country of the European Economic Area (EEA), please refer to the additional information provided in the section 11 “Users in the EU / EEA”.

2 Contacting our Data Protection Officer

If you have any questions or concerns on data protection with regards to Sourceability Germany (Sourceability Vertriebsgesellschaft mbH), please contact the Data Protection Officer of Sourceability Germany, Dr. Alexander Theusner, at Rödl GmbH Rechtsanwaltsgesellschaft, Äußere Sulzbacher Straße 100, 90491Nürnberg, Germany, or preferably by e-mail to: emea.datasecurity@sourceability.com.

If you have any questions or concerns on data protection with regards to other Sourceability Entities, please contact us at legal@sourcengine.com.

3 Collection of your Information

Sourceability asks for specific types of Personal Data (as defined below), which enables Sourceability to adequately identify you, process your sale or your purchase, provide services to you, provide marketing material (such as email newsletters) to you, enhance your Website visit, respond to requests for information, support your relationship with Sourceability, assist you with technical support issues and/or to follow up with you after your visit to the Website.

Sourceability collects data through your interactions with Sourceability, such as when:

  • you visit the Website and use the Services provided through the Website;
  • you register for an Account;
  • an order is placed to purchase products;
  • products are placed with Sourceability for sale;
  • you request us or you consent with us providing you marketing material (such as email newsletters);
  • an enquiry is made or feedback is given.

Sourceability may ask for and/or obtain some of the following data: your name, address, e-mail address, IP address, phone number(s), occupation, designation, national identification number(s) or passport number(s), order history, credit card information and other bank details, referrals, or other information that is needed to process your transaction or request. Sourceability may also collect demographic information including details of your business or company, age, gender, and product sale or purchase history. Collectively, the items described herein are "Personal Data".

Sourceability may collect information relating to your online interactions with Sourceability (including, but not limited to, your IP address, the pages you view, website links and advertisements that you click on) so that Sourceability can offer you a more consistent and personalized experience with Sourceability and better serve your needs by tailoring the content, services and marketing material that Sourceability shares with you.

Your Personal Data may be held or stored in any or a combination of the following, in the United States of America:

  • Computer systems;
  • Cloud systems;
  • Electronic databases;
  • Digital archives;
  • Telephone recordings; and
  • Hard copy or paper files.

These storage mechanisms may be managed by Sourceability or by Amazon Website Services (AWS) with whom Sourceability has a contractual relationship. For more security and compliance informationabout AWS, please read about Amazons security features and compliance from: https://aws.amazon.com/security/ & https://aws.amazon.com/compliance/

The Personal Data you provide will be kept confidential and will only be stored, used and disclosed for the purposes for which it was collected or as otherwise permitted by applicable law. It is collected and processed for the following general purposes or for other lawful business purposes:

  • To operate our Website;
  • To register you as a member of the Website;
  • To process your purchase;
  • To fulfill requests for products and services;
  • To improve our products and services;
  • To contact you;
  • To provide you with marketing material;
  • To prevent and/or to avoid fraud and other prohibited or illegal activities;
  • To protect the security or integrity of the Website, our business, our products or services;
  • To customize our communication with you and the marketing materials Sourceability shares with you; and
  • To improve and develop our Website in order to better provide our services to you.

4 When Sourceability will Share your Personal Data

Your Personal Data may be shared with other Sourceability entities, agents or contractors performing services for Sourceability to the extent necessary in order for Sourceability to provide services to its customers. If so, Sourceability will ensure that your Personal Data is only used in connection with the functions these parties will be performing for Sourceability and that all such information is treated in a confidential manner. Sourceability will disclose your Personal Data to the extent required by applicable law, if ordered or required to do so by a court or relevant enforcement authority, or to ensure that Sourceability is in compliance with its legal obligations.

5 Your Rights

To request any update or correction of your Personal Data, please contact our Data Privacy Officer at legal@sourcengine.com.

Upon receipt of your request and within a reasonable period of time, Sourceability will make the requested update or correction or cease to process your Personal Data accordingly.

6 Cookies

In order to provide you with a customized experience, Sourceability uses Sourceability and third party cookies to help Sourceability determine which information is relevant and to enhance your experience when you interact with Sourceability. Cookies are small files that are placed on your computer when you visit a website. Cookies may be used to store a unique identification number tied to your computer or device so that you can be recognized as the same user across one or more browsing sessions, and across one or more sites. Cookies serve many useful purposes. For example:

  • Cookies can remember your sign-in credentials so you do not have to enter those credentials each time you use our Website.
  • Cookies can help Sourceability and third parties understand which parts of our Services and our Website are the most popular because they help us see which pages and features visitors access and how much time they spend on the pages. By studying this kind of information, Sourceability is better able to adapt the Services and provide you with a better experience.

Most browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. If you disable browser cookies or flash cookies, it may interfere with the proper functioning of the Website and the Services.

7 Web Beacons

Sourceability, or third parties acting on our behalf, may use web beacons or related technology on theWebsite, in our communications, on other sites, or in Sourceability's communications in others' messages. A web beacon is an electronic image that can be used to recognize a cookie on your equipment when you view a web page or online communication. Web beacons help Sourceability measure the effectiveness of the Website and Sourceability's interactions with you in various ways, for example, by counting the number of individuals who visit our site from a particular communication or who make a purchase from our site as well as by telling Sourceability when a web page is viewed and providing a description of the page where the web beacon is placed. Web beacons also help Sourceability measure the effectiveness of our communication campaigns, for example, by counting the number of individuals who open or act upon a message, determining when a message is accessed and determining how many times a message is transmitted onwards. The information Sourceability collects may include Personal Data, and web beacons allow Sourceability to recognize users by accessing Sourceability cookies. Sourceability may also combine the information that Sourceability collects through web beacons with other personal information that Sourceability has collected from you. Sourceability uses all of this information to better tailor our interactions with you and Sourceability may use this information for other purposes, such as to enable a shopping cart, customize content on the Website and for internal research purposes. Sourceability will not share any personal information collected through the web beacons with any third party, except for service providers who act on our behalf and who are contractually prohibited from any other use or disclosure of the information. Sourceability allows third parties to place their own web beacons on the Website if they share Sourceability's commitment to protecting your privacy and data. You can make some web beacons unusable by rejecting cookies.

8 Third-Party Sites

Please be aware that other websites including sites that may be accessed through our site, e.g., via a hyperlink, may collect personal information about you. This Policy does not cover the information practices of those third-party sites linked to the Website.

9 Additional Information

If you have asked to be contacted by one of Sourceability's partners, Sourceability will need to provide them with your contact details. This information will not be shared with any other party and will be forwarded to that partner for the sole purpose of allowing them to contact you.

10 Assignment

We may assign our rights and duties under this Policy, including, without limitation, our rights in information collected through the Website, to any third party at any time without notice to you in connection with any sale, merger, acquisition, divestiture or liquidation of all or part of our business or assets related to the Website, all or substantially all of our business or assets, or as part of any reorganization or restructuring of our business.

11 Users in the EU / EEA

If you use the Website and our Services in the European Union (EU) or another country of theEuropean Economic Area (EEA), the following information applies with respect to Personal Data collected through your use of the Website and/or our Services. Under the applicable EU General DataProtection Regulation (the “GDPR”), you have certain additional privacy rights. The following provisions of this Section provide information about these additional rights and further information under the GDPR.

Controller: Sourceability SG Pte. Ltd. and Sourceability North America LLC are considered as“controllers” of the Personal Data collected through your use of our Website and/or our Services, and are acting as joint controllers.

Our Representative in the EU: You may also contact us via our designated representative in the EU by email at emea.datasecurity@sourceability.com or by post at

Sourceability Vertriebsgesellschaft mbH
Heisenbergbogen 2
85609 Aschheim
Germany

Your Rights under the GDPR:

You have a number of rights concerning your Personal Data that Sourceability holds and uses, including the following:

  • Right of Access – You have the right to be informed about what personal information Sourceability holds about you and to a copy of this personal information.
  • Right to Rectification – You have the right to have any inaccurate personal information which Sourceability holds about you updated or corrected.
  • Right to Erasure – In certain circumstances you may request that Sourceability delete the personal information that Sourceability holds about you.
  • Right to Complain – You have the right to lodge a complaint regarding the processing of your personal information to an applicable governmental or supervisory authority in your country.
  • Right to Object – Where Sourceability relies on our legitimate interests to process your personal information, you have the right to object to such use and Sourceability is required to discontinue such processing unless Sourceability can demonstrate an overriding legitimate interest in such processing.
  • Right to Restriction – You have the right to request that Sourceability stop using your personal information in certain circumstances including if you believe that the personal information Sourceability holds about you is inaccurate or that Sourceability’s use of your personal information is unlawful. If you validly exercise this right, Sourceability will store your personal information and will not carry out any other processing until the issue is resolved.

To assert these rights, please use the contact options listed under the point “Controller” and “Our Representative in the EU” above or the contact forms shown below.

Notice of Consent: https://sourceability.com/gdpr/notice-of-consent

Data Subject Request: https://sourceability.com/gdpr/data-subject-request

Request of Data Removal: https://sourceability.com/gdpr/request-of-data-removal

The contact forms can also be found on the websites: https://www.sourcengine.com/gdpr and https://www.sourceability.com/gdpr.

Purposes of Processing and Legal Basis for Processing:

We process your Personal Data consistent with our disclosures in our Policy. When processing your Personal Data, Sourceability may rely on one or more of the following legal bases (or other available legal grounds), depending on the circumstances:

Period of Storage of Personal Information: Sourceability’s policy is to store your Personal Data only for as long as is necessary to fulfill the purposes for which Sourceability collected such personal information, including for the purposes of satisfying any professional, legal, accounting or reporting requirements to which Sourceability is subject. To determine the appropriate retention period for personal information, Sourceability considers the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which Sourceability collected and processed your personal information and whether Sourceability can achieve those purposes through other means, and any applicable legal and professional requirements.

Right to Object and Withdraw Your Consent to the Processing of Your Personal Data

If you have given your consent to the processing of your Personal Data, you can withdraw your consent at any time. If you withdraw your consent, we are not allowed to process your Personal Data after the withdrawal. Withdrawing your consent does not affect the lawfulness of processing based on consent before the withdrawal.

If the processing of your Personal Data is based on our Legitimate Interests, you may object to the processing. In the event of your objection, we request you to explain the reasons why we should not process your Personal Data as we have done. If your objection states reasons, we will examine the situation and will either stop or adjust the data processing, or will demonstrate our compelling legitimate reasons that allow us to continue the processing.

Right to Complain to the Supervisory Authority in the EU: In addition, you have the right to lodge a complaint with a competent supervisory authority in the EU.

Use of Social Media Plug-Ins and Tracking on our Website

On our Website, we currently use the following social media plug-ins: Facebook, LinkedIn, Twitter and Xing. No personal data is transferred to the providers of these plug-ins when you initially visit ourWebsite. You can identify the providers of the plug-in by buttons that show the providers’ logos. Only if you click on the button, the plug-in provider will receive the information that you have accessed the corresponding page on our website. We have no influence on the collected data and data processing operations of the plug-in providers, nor are we aware of the full extent of data collection, the purposes of the processing and the periods for which the data will be stored. We also have no information about the erasure of the data collected by the plug-in providers.

The plug-in providers store your personal data that they have collected as user profiles and use them for purposes of advertising, market research and / or tailor-made website design. Such evaluation is carried out in particular (also for non-logged-in users) for the presentation of targeted advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles. To object, you must contact the respective plug-in provider. By using the plug-ins we give you the opportunity to interact with the social networks and with other users, so that we can improve our services and make them more interesting for you as a user. The data transfer takes place regardless of whether you have an account with the plug-in provider and are logged into it.

For more information on the purposes and scope of the data collection and its processing by the plugin providers, please refer to the privacy statements of these providers as provided below. Therein, you will also find further information about your rights and settings options for the protection of your privacy:

Facebook: Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland; http://www.facebook.com/policy.php.

LinkedIn: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; http://www.linkedin.com/legal/privacy-policy.

Twitter: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07Ireland; https://twitter.com/privacy

Xing: New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany; https://privacy.xing.com/datenschutzerklaerung

Use of Google Analytics

Our Website uses Google Analytics, a web analytics service provided by Google Inc. ("Google").Google Analytics uses cookies. The information generated by the cookie about your use of thisWebsite is usually transmitted to a Google server in the USA and stored there. However, if IP anonymization is activated on this Website, your IP address will be truncated beforehand by Google within member states of the EEA. Only in exceptional cases the full IP address will be sent to aGoogle server in the USA and truncated there. On behalf of Sourceability, Google will use this information to evaluate your use of the Website, to compile reports on website activity and to provide other services related to website usage and internet usage to Sourceability. The IP address transmitted by Google Analytics as part of Google Analytics will not be merged with other data provided by Google.

This Website uses Google Analytics with the extension "_anonymizeIp ()". As a result, IP addresses are processed in truncated form. This means that they do no refer to a person anymore.

We use Google Analytics to analyze and improve the use of our Website. With the statistics we can improve our services and make them more interesting for you as a user. The legal basis for the use ofGoogle Analytics are our Legitimate Interests.

Third-party information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4,Ireland. Terms of Use: http://www.google.com/analytics/ terms / en.html, Privacy Policy: http://www.google.com/intl/de/analytics/learn/privacy.html, and the Privacy Policy: http://www.google.com/intl/en/ policies / privacy.

This Website also uses Google Analytics for a cross-device analysis of visitor flows conducted through a user ID. You can disable the cross-device analysis of your use in your My Account under"My Data", "Personal Information".

Use of Google reCAPTCHA

On our Website, we use Google reCAPTCHA to check and avoid interactions on our Website through automated access, for example through so-called bots. Through this service, Google can determine from which website a request is sent and from which IP address you use the so-called reCAPTCHA input box. In addition to your IP address, additional information may be collected by Google, which is necessary for the offer and the guarantee of this service. We use this service in order to enhance the security of our Website and in the defense against unwanted, automated access in the form of spam or the like. The legal basis for this service are our Legitimate Interests. For more information on the purposes and scope of the data collection and its processing by Google, please refer to its privacy notice. The address, and URL of Google’s privacy notice are shown in the section on Google reCAPTCHA above.

Use of New Relic

Our Website uses a plugin of the web analysis service New Relic Inc. (“New Relic”). This plug in enables us to make statistical evaluations about the use and speed of our Website. It provides NewRelic the information that a user has accessed the respective webpage of our Website, as well as further information about the use of the Website. In addition to your IP address, cookie-generated information about your use of our Website is typically transmitted to and stored on a New Relic server located in the United States. We use New Relic to analyze and improve the use of our Website. With the statistics we can improve our services and make them more reliable. The legal bases for the use of this plug-in are our Legitimate Interests.

Third-party information: New Relic Inc., Suite 1200,188 Spear Street, San Francisco, CA 94105,USA. Privacy Policy: https://newrelic.com/privacy.

Use of Hub Spot

On our Website we also use a plugin of the inbound marketing service HubSpot provided by HubSpotInc. (“HubSpot”). HubSpot collects and analyzes data of your use of our Website. In addition to yourIP address, cookie-generated information about your Website use is typically transmitted to and stored on a HubSpot server located in the United States. We use HubSpot to improve our inbound marketing and to make our services more interesting for our Website users. The legal bases for the use of this plug-in are our Legitimate Interests.

Third-party information: HubSpot, 25 First Street, 2nd Floor Cambridge, MA 02141, USA. PrivacyPolicy: https://legal.hubspot.com/de/privacy-policy.

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