May 25, 2018.
GeoCerts is a company established in the United States with principal offices at 2221 Peachtree Rd NE, Suite D, PMB 236, Atlanta, GA 30309 and for the purpose of the General Data Protection Regulation (“GDPR”) and any local data privacy laws, we are the data controller of personal information obtained through our Website. We are a data processor in relation to the Individuals’ personal information that we receive from Customers (data controllers), either directly or through resellers, and that we process at the Customer’s instructions, as well as according to applicable Baseline Requirements for the Issuance and Management of Publicly-Trusted Certificates (“Baseline Requirements” or “Industry Standards”), in order to issue Certificates.
Information that GeoCerts Receives
Through our Website: GeoCerts collects information such as the name, organization, and email address of Website visitors and Customers who voluntarily submit that information via our Website, email, instant chat, by creating an account or otherwise, in order to download software or to submit sales or technical support questions.
From Customers: Customers request GeoCerts Certificates through their account in GeoCerts' Website (the “Account”). When submitting a request, Customers provide to GeoCerts the following information about Individuals: name, email address, telephone number, address, employee title, Dun & Bradstreet (DNB, D&B, DUNS) Number, European Union Value Added Tax (EU VAT) number, and government-issued identification (which may include additional information, depending on the identification used).
Where Customers share personal information of Individuals with GeoCerts, Customers represent that they have collected and processed such information in accordance with data protection laws, and that they have duly informed the Individuals that their personal information was provided to GeoCerts. GeoCerts will process such information following Customer instructions, as strictly necessary to provide the services contracted by Customer.
Use of Information
We will use your information to:
Provide products and services, live chat, sales, support: As it is in our legitimate interest to market, sell and provide our products and services, send order confirmations, respond to Customer service requests, provide chat services with sales questions and technical support needs, and fulfill your order, including using the information to verify the identity of the Customer or to contact the customer in order to discuss support, renewal, and the purchase of products and services.
Marketing: We will use your information as is in our legitimate interests to send out promotional emails (subject to seeking your consent where required by applicable law). These emails include beacons that communicate information about the email back to GeoCerts. Such tracking allows GeoCerts to gauge the effectiveness of its advertising and marketing campaigns. Recipients can opt-out of receiving promotional communications from GeoCerts by following the unsubscribe instructions provided in each email or by emailing email@example.com. GeoCerts may use third parties, with which it has a confidentiality agreement, to send promotional emails on our behalf. However, GeoCerts restricts its partners from sending spam associated with GeoCerts' site, brand, or products. Anyone receiving an unsolicited email related to GeoCerts' products and services should forward the entire message and headers to firstname.lastname@example.org.
Advisory emails: While a customer account is active, GeoCerts will send advisory emails to customers to provide support and security updates in relation to our products and services, as this is necessary for the performance of our contracts with customers. Advisory emails are used to respond to inquiries, provide support and validation services, provide upgrade information and security updates, and inform the customer about ordered products and services. Because advisory emails contain essential information related to the use and security of GeoCerts' products and services, customers are not able to unsubscribe from advisory service emails while their customer account is active.
- Technical usage information: As it is in our legitimate interests to ensure the proper functioning of our Website by personalizing its use, monitoring usage activity and trends, and keeping the website safe and secure, when you visit the Website, we collect the information sent to us by your computer, mobile phone, or other access device. This information includes: your IP address; device information including, but not limited to, identifier, name, and type of operating system; mobile network information; and standard web information, such as your browser type and the pages you access on our Website.
Cookies & Tracking Technologies
Sharing with Third Parties
GeoCerts will publicly disclose information embedded in an issued Certificate as necessary to provide the services contracted by Customer, in accordance with Industry Standards.
When performing its services, GeoCerts uses third party sources to confirm or supplement the information that it obtains from a Customer, including information about Individuals. GeoCerts uses such information from third party sources exclusively for the purposes of its Validation Services, based on the legitimate interests of GeoCerts and of the Customer to provide services and have a Certificate issued.
GeoCerts never sells or provides personal information to third parties for uses apart from assisting GeoCerts in servicing our Customers and website visitors. We will share your personal information with third parties including these categories of recipients:
- IT Services providers that provide us with SaaS services including Salesforce/Desk who we use to store our customer relationship management and support information;
- Marketing providers, advertisers and advertising networks that require the data to send you advertisements about our products and select and serve relevant adverts to you and others;
- Analytics and search engine providers that assist us in the improvement and optimization of the Website;
- Chat-based support software services that allow users to input information, including an email address, to request support and clarify their problem; and
- Credit card and payment providers that help process payments for us (note that we do not store any provided credit card information).
GeoCerts will share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, including to meet national security or law enforcement requirements, or if we have a good faith belief that such use is reasonably necessary to:
- comply with a legal obligation, process or request;
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law.
GeoCerts will also disclose your information to third parties:
- in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; or
- if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.
If you choose to use our referral service to tell a friend about our Website, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting them to visit the site. GeoCerts collects this information for the sole purpose of sending this one-time email and tracking success of the referral program.
If you believe that one of your contacts has provided GeoCerts with your personal information, you may contact us at email@example.com to request that we remove this information from our database.
Our Website offers publicly accessible blogs or community forums. Any information you provide in these areas can be read, collected, and used by others who access them.
To request removal or your personal information from our blog or community forums, please contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why, as well as additional contact information when applicable.
Social Media Widgets
The security of your personal information is of the utmost importance to GeoCerts. GeoCerts only transmits personal information, including sensitive information (such as credit card data), using transport layer security (TLS). To learn more about TLS, follow this link:https://www.geocerts.com/blog/tls-13-is-here.
Unfortunately, no method of transmission over the Internet or electronic storage is 100% secure. While GeoCerts strives to use commercially acceptable standards to protect personal information, GeoCerts cannot guarantee absolute security. If you have any questions about the security of your personal information, please contact us at email@example.com.
We take all necessary security and legal precautions to ensure the safety and integrity of the Individuals’ personal data that we receive from Customer, including, as appropriate, (i) the pseudonymization of personal data; (ii) ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services; (iii) restoring the availability and access to personal data in a timely manner in the event of a physical or technical incident; and (iv) regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.
Where We Store Your Data
GeoCerts, Inc. is based in the United States and our Website is hosted in the United States. Therefore, if you are located outside the United States, the information that you submit to us through our Website will be transferred to the United States. Likewise, Customer data and your personal data will be accessible from and transferred to the United States.
Where you have a dispute or complaint regarding GeoCerts' collection, storage, or use of your personal information, you may make a complaint to GeoCerts by sending it to firstname.lastname@example.org. If you are an EU resident, where the dispute or complaint is not satisfactorily resolved or you don’t receive a timely response, you may escalate the matter to your European data protection authority free of charge, and GeoCerts commits to cooperate with the relevant European data protection authority and will comply with the advice given by this authority with regard to your information which was transferred from the European Union in the context of this Website. For EU residents, such complaint is without prejudice to your right to launch a claim with the data protection supervisory authority in the EEA country in which you live or work.
Individual Rights over Personal Information
Generally, a Customer or Individual can review, delete inaccuracies, and update personal information through its GeoCerts account interface by clicking Manage Account link.
In certain circumstances, individuals also have the following rights:
Access and portability: You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
Correction, erasure and restriction of processing: You have the right to require us to correct any personal data held about you that is inaccurate and have incomplete data completed or ask us to delete data (i) where you believe it is no longer necessary for us to hold the personal data; (ii) where we are processing your data on the basis of our legitimate interest and you object to such processing; or (iii) if you believe the personal data we hold about you is being unlawfully processed by us. You can ask us to restrict processing data we hold about you other than for storage purposes if you believe the personal data is not accurate (whilst we verify accuracy); where we want to erase the personal data as the processing we are doing is unlawful but you want us to continue to store; where we no longer need the personal data for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims or where you have objected to us processing personal data and we are considering your objection.
Customers and Individuals cannot edit a GeoCerts Certificate issued by it's CA partners (DigiCert, Symantec, GeoTrust, Comodo CA, Thawte, RapidSSL, et al.) directly. In order to update information in a Certificate, including personal information, Customers or Individuals must submit a change request through the Customer’s Account, and GeoCerts will implement the edits where applicable.
Objection: You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.
Testimonials: With prior permission from the customer, GeoCerts displays personal testimonials of satisfied customers on our Website in addition to other endorsements. Customers wishing to update or delete a testimonial should contact GeoCerts at email@example.com.
Marketing: You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing at any time by contacting us at firstname.lastname@example.org.
- Complaints: In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at email@example.com and we will endeavor to deal with your request. If you are an EU resident, this is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.
You can exercise these rights by sending an email to firstname.lastname@example.org or by mailing GeoCerts at the address listed in this policy. Before we respond to your request, we will ask you to verify your identity. Note that these rights in their entirety only apply to EU residents and subject to the applicable law of the jurisdiction where you reside. Where exercise of a particular data subject right is not required by law, your request will be handled on a case-by-case basis.
How Long We Store Your Data
We will retain your information as follows:
- Account data (including to send Advisory emails): As long as the account is active, while a Certificate remains unexpired, and in accordance with industry standards, which requires us to maintain the data for 7.5 to 10.5 years after account cancellation. In addition, after account cancellation, we will keep this for as long as necessary to defend against legal claims, resolve disputes or enforce customer agreements.
- Data collected through Website analytics: up to 26 months.
- Data provided for marketing purposes: until you notify us that you no longer want us to use your information for marketing purposes, by unsubscribing from any marketing email you receive or by contacting email@example.com.
After you have terminated your use of our services, we may store your information in an aggregated and anonymized format.
Our website includes links to third party websites whose privacy practices may differ from those of GeoCerts. If you submit personal information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policies of those third-party websites before you submit any information to those websites.
GeoCerts, Inc. Headquarters
Attention: Global Data Protection Coordinator
2221 Peachtree Rd, NE
Suite D, PMB 236
Atlanta, GA 30309
By phone or fax:
Toll Free: 1-800-892-7095 (US & Canada)
Fax Toll Free: 1-800-892-7095 (US & Canada)
Fax Direct: 1-404-424-9753
For assistance with technical difficulties, including problems with accessing or using your customer account, please email firstname.lastname@example.org.
As noted above, if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact GeoCerts.