LAST UPDATED: APRIL 3, 2020
Collection of Information
Information You Provide to Us
We collect personal information that you provide directly to us, including through our website or when you contact us with respect to our programs or initiatives. This may include your name, email address, phone number, online profile, log information, geography, demographic information, your opinions and preferences, resume and other job application information, and any other information you choose to provide.
Information Provided by Third Parties or Publicly Available Sources
Information You Provide to SIP
SIP collects personal information that you provide directly to SIP, including through its website or when you contact SIP with respect to programs or initiatives. This may include your name, email address, phone number, online profile, log information, geography, demographic information, your opinions and preferences, resume and other job application information, and any other information you choose to provide.
Information Provided by Third Parties or Publicly Available Sources
Information collected by SIP’s contractors: SIP uses contractors to provide it with services. When contractors are collecting personal information on behalf of SIP, SIP expects to put in place additional measures to limit the personal information provided by the contractor to SIP. For example, if SIP hires a survey company to carry out surveys on its behalf, SIP expects to instruct the contractor to provide SIP only with aggregate, non-identifying information.
Potential acquisitions: SIP may also process information in relation to companies that it is evaluating in connection with a potential acquisition of or investment in such companies. This personal information is obtained via third parties (e.g., the company in question).
Information SIP Collects Automatically
When you use a SIP website, SIP may automatically collect information including personal information, such as:
Log Information: SIP may collect log information about your use of our website, including the type of browser and device you use, access times, pages viewed, your IP address, links clicked, and conversion information and the page you visited before navigating to a SIP website.
Information Collected by Cookies and Other Tracking Technologies: SIP may use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help SIP improve its website and your experience, see which areas and features of its websites are popular, and count visits. Web beacons are electronic images that may be used in a website or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. This information is used to improve website performance and for SIP’s business purposes. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used, and how you manage your cookie preferences.
Use of Your Information
To the extent that you provide SIP with, or SIP otherwise collects, any personal information, SIP may use your personal information for the following purposes:
- Provide and improve websites and services, and to develop new services
- Produce aggregate data to share with the public and other stakeholders
- Evaluate your job application and consider you for employment
- Respond to your comments, questions, or requests
- Communicate with you about news and information SIP thinks will be of interest to you
- Monitor and analyze trends, usage, and activities in connection with the use of the website
- Administer the security of the website and protect other users, the public, and SIP
When SIP solicits additional information, such as in connection with employment opportunities or community engagement, SIP will provide information to you at the time about the purposes for which information is being collected, used, or disclosed. SIP collects, processes, and uses such information for various legal reasons, including to protect its legitimate interests, for contractual necessity (including to provide you services that you have requested), or because SIP is required by law.
Sharing of Information
Some of SIP’s websites or services may allow you to share your personal information. You have control over how you share your information using these features.
SIP uses reasonable measures to keep your personal information safe. SIP may share your personal information with affiliates and other contractors that collect and use your personal information on SIP’s behalf, including professional advisors, recruitment firms, consultants, service providers, and data hosting providers, and in some instances, placement agents and other administrators. These contractors may use your personal information only to perform the functions they carry out on SIP’s behalf, in compliance with appropriate confidentiality and security measures. SIP requires that they enter into agreements with SIP and protect your personal information at the same high level as SIP does.
SIP reserves the right to disclose your personal information as required by law or when SIP believes that disclosure is necessary to protect its rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving SIP. Should SIP, or any of its affiliated entities, be the subject of a takeover, divestment, or acquisition SIP may disclose your personal information to the new owner of the relevant business and their advisors.
Transfer of Information to Other Countries
Your personal information may be held outside of the jurisdiction of your residence or of your use of SIP’s products and services, where it will be subject to foreign laws. To the extent that EU data protection legislation applies to the transfer of your personal information, including transfers of personal information to countries outside of the EEA, such transfers will only be conducted in accordance with EU data protection legislation.
Security and Retention of Personal Information
SIP is committed to protecting the personal information you entrust to it. SIP adopts robust and appropriate technologies and policies, so the information it has about you is protected to the extent possible from unauthorized access and improper use. In addition, SIP limits access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know, are subject to a duty of confidentiality, and will only process your personal data on SIP’s instructions. SIP will retain your personal information for as long as necessary to fulfill the purposes for which it was collected and as required by law.
SIP may send you direct marketing communications to keep you informed of our business and operations in which you might be interested, subject to any applicable required prior consent, based on SIP’s legitimate business interests where it has an existing relationship with you and wishes to contact you about similar products or services in which you may be interested. You may opt-out of such marketing communications if you do not wish to receive them.
This website is only intended for individuals who are at least 13 years of age. SIP does not knowingly encourage or solicit visitors to this site who are under the age of 13 or knowingly collect personal information from anyone under the age of 13 without parental consent.
Your Access and Correction Rights
You may access, correct, and control your personal information that SIP processes, in each case to the extent provided by applicable law. To the extent SIP processes any of your personal information that is not subject to EU data protection legislation, you can request access to such personal information by contacting email@example.com. SIP will promptly respond to your request unless we are prohibited to do so by law, in which case SIP will justify its refusal. To the extent SIP processes any of your personal information that is subject to EU data protection legislation, you have the right to access and control, in the ways set forth below, your personal information that SIP holds. To exercise these rights, please contact firstname.lastname@example.org.
Access: You have the right to ask for a copy of the personal information that SIP holds about you free of charge, though SIP may charge a ‘reasonable fee,’ if it thinks that your request is excessive, to help it cover the costs of locating the information you have requested.
Correction: You may notify SIP of changes to your personal information if it is inaccurate or it needs to be updated.
Deletion: If you think that SIP should not be holding or processing your personal information any more, you may request that SIP delete it. Please note that this may not always be possible due to legal obligations.
Restrictions on use: You may request that SIP stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that SIP no longer needs your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and SIP is verifying whether our legitimate grounds to process your personal information, override your own rights.
Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask SIP to do so, and SIP will send it directly if we have the technical means.
Withdrawal of consent: If you previously gave SIP your consent (by a clear affirmative action) to allow SIP to process your personal information for a particular purpose, but you no longer wish to consent to SIP doing so, you can contact SIP to let it know that you withdraw that consent.
SIP may need to request specific information from you to help it confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. SIP may also contact you to ask you for further information in relation to your request to speed up its response.
Notification of Changes
Should you wish to lodge a complaint with regards to how your personal information has been processed by SIP, please contact your local supervisory authority.