Sourceability Privacy Policy                                                                                                         

This Privacy Policy was last updated on, and is effective as of, July 12, 2018.

Sourceability North America LLC (“Sourceability”, “we”, “us” and “our”), a Delaware limited liability company with its registered office address at 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808owns and operates the Sourceability 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.

By accepting the Policy when providing Personal Data through our Website (the “Account“) in order to use the services provided through the Website (the “Services“), you expressly consent to our collection, storage, use and disclosure of your Personal Data (as defined below) 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 authorised to access the Website and use the Website and (ii) the company itself.

Changes to Privacy Policy

Sourceability reserves the right to modify the Policy to reflect changes in applicable law or for any other reasons deemed appropriate by Sourceability. Any modifications to the Policy shall apply immediately upon such modified Policy being posted on the Website.  We will post at the top of this Policy the date that modifications were last made, which should alert you to any changes since your last visit to the Website.

General Statement About Privacy

Sourceability respects your privacy. For our business, Sourceability will collect, store and use your Personal Data (as defined below)for defined purposes. Sourceability uses your Personal Data (as defined below)to support and enhance our relationship with you, for example, to enable our department for human resources to process your employment application and to interact with you, to contact you to resolve any issues, to provide service and support, and share information with you.

Collection of Your Information

Sourceability asks for specific types of Personal Data (as defined below), which enables Sourceability to adequately identify you, process your requests, provide services to you, enhance your site 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 Website provided through the Website;
  • you submit your job application through our Website;
  • an enquiry is made or feedback is given;
  • an enquiry is made through the embedded Octopart service on the Website.

Sourceability may ask for and/or obtain data such as your name, address, e-mail address, IP address, phone number(s), occupation, designation, national identification number(s) or passport number(s), resume details, order history, referrals, and 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 Datamay be held or stored in any or a combination of the following, in the United States of America or outside 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 a third party service provider with whom Sourceability has a contractual relationship.

Sourceability will take reasonable steps to protect your Personal Datafrom misuse, interference and loss, as well as unauthorized access, modification or disclosure, includingtechnical, administrative and organizational security measures for the Website that we believe are commercially reasonable to help achieve such purposes.  However, you should be aware that the transmission of information via the Internet is not completely secure.  Although we will use commercially reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted using the Website, and as a result, any transmission of personal data is at your own risk.

Purposes For Which Sourceability Uses Your Personal Data

The Personal Datayou 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 and for other lawful business purposes:

  • To process your employment application;
  • To fulfill requests for products and services;
  • To improve our products and services;
  • To contact you;
  • 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.

When Sourceability Will Share Your Personal Data

Your Personal Datamay be shared with other Sourceability entities, agents or contractors performing services for Sourceability to the extent necessary in order for Sourceability to process your employment application or provide services to you. If so, Sourceability will seek to ensure that your Personal Datais 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 Datato 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.

Personal Data Update Requests

To request any update or correction of your Personal Data, please contact Sourceability at:

Email address: dataprotectionofficer@sourceability.com

Contact person: Mr. Nader Dibai

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 Dataaccordingly.

Cookies

In order to provide you with a customised experience when using our Website, 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 through our Website.

Web Beacons

Sourceability, or third parties acting on our behalf, may use web beacons or related technology on the Website, 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 we have determined that such third parties share Sourceability’s commitment to protecting your privacy and data. You can make some web beacons unusable by rejecting cookies.

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 privacy statement does not cover the information practices of those third-party sites linked to the Website.

Additional Information

If you have asked to be contacted by one of Sourceability’s business 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.

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.

ADDITIONAL NOTICES TO CALIFORNIA RESIDENTS

California Do-Not-Track Disclosure.  At this time, our website is not set up to honor web browser do-not-track settings.

Information on Marketing Disclosures.  California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at Sourceability, Attn: Data Protection Officer, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808or at dataprotectionofficer@sourceability.com.

Content Removal Requests for Users Under 18 Years Old.   If you are a user under 18 years of age and reside in California, you may request and obtain removal of, content or information that you have posted on our website.    You may send us any such requests by one of the following methods: (i) by email (writing “Policy – Removal Request” in the subject line) at dataprotectionofficer@sourceability.com; or (ii) by writing to us at Sourceability, Attn: Data Protection Officer, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808. We will review the request and respond promptly. You should be aware that a request to remove content or information posted by you on the website does not ensure or require complete or comprehensive removal of such content or information from our databases.

ADDITIONAL NOTICES TO EUROPEAN UNION RESIDENT AND OTHER DATA SUBJECTS

 Persons who are residents of the member countries of the European Union (“EU”) or other data subjects covered by the EU’s General Data Protection Regulation, (EU) 2016/679 (the “GDPR”), have certain additional privacy rights under applicable law. The following provisions of this Section 12 provide an overview of these additional rights.

 

Our Commitment

Sourceability embraces the approach to privacy protection reflected in the GDPR, giving our clients, vendors, and users a greater say in what happens with their data. To this end, we have undertaken a number of important updates and steps. including:

  1. Transparency of Data– Sourceability has enhanced the Website for increased readability behind its data access processes. Sourceability has made the path to your data easily available per your request.
  2. Data Security – Sourceability implements high redundancy among its servers and leverages the information protection tools within the Microsoft Azure platform to identify personal data, monitor access, and govern security protocols.
  3. Compliance & Preparation– Sourceability adheres to ISO 9001:2008 standards.

Please visit our GDPR information page  or contact our data protection officer at dataprotectionofficer@sourceability.com if you have any questions about any matters related to our GDPR compliance.

 Legal Bases for Processing Personal Information of European Union Citizens or Other GDPR Data Subjects

When processing your personal information, Sourceability may rely on one or more of the following legal bases (or other available legal grounds), depending on the circumstances:

  • Legitimate Interests – Sourceability may process your personal information where Sourceability has a legitimate interest in such processing for managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights or freedoms.
  • Consent – Sourceability may process your personal information where Sourceability has obtained your consent to the processing.
  • Contractual Necessity – Sourceability may process your personal information where such processing is necessary in connection with any contract that Sourceability has with you.
  • Legal Requirements – Sourceability may process your personal information where such processing is required by applicable law.

Disclosures to Third Parties

 Your personal information will not be disclosed to third parties except where it is necessary for fulfillment of Sourceability’s obligations to you or where Sourceability is obliged or permitted to do so by law (including, without limitation, through the terms of any agreement Sourceability may have with you), or where Sourceability makes disclosures that are otherwise consistent with the uses described in this Policy.

Sourceability may also disclose any information (including personal information) relating to you to law enforcement authorities or any regulatory or government authority in response to any request including requests in connection with the investigation of any suspected illegal activities.

Sourceability reserves the right to transfer any personal information Sourceability has about you in the event Sourceability sells or transfers all or a portion of our business or assets, or merges with another organization. Should such a sale, transfer or merger occur, Sourceability will use reasonable efforts seeking to require that the transferee uses personal information you have provided to Sourceability in a manner that is consistent with this Policy.

Sourceability will not sell, resell or lease your personal information to any third parties but Sourceability may, if required for the purpose(s) for which your personal information was collected and processed, share it with Sourceability partners and/or service providers to enable them to provide their services to Sourceability or to you, as applicable. The foregoing are in addition to the other uses described elsewhere in this Policy.

Security of Personal Information of European Citizens or Other GDPR Data Subjects

 Sourceability has policies and technical and organizational measures in place which are intended to safeguard and protect your personal information against unauthorized access, accidental loss, improper use and disclosure. However, you should be aware that information transmitted over the internet is not completely secure because of the nature of the internet and that systems and measures used to secure information are not flawless. For these reasons, although Sourceability will use reasonable efforts to protect your personal information, Sourceability does not warrant the security of personal information transmitted to Sourceability or stored by Sourceability, and personal information that is transmitted to Sourceability by you electronically is done at your own risk.

Retention of Personal Information of European Citizens or Other GDPR Data Subjects

Sourceability’s policy is to retain your personal information 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. 

Your Rights as a European Resident or Other GDPR Data Subject

 You have a number of rights concerning your personal information 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.

(d)   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 Withdraw Consent – Where processing of personal information is based on your consent, you have the right to withdraw such consent at any time.
  • 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.

You may exercise any of the above requests in writing to Sourceability, Sourceability, Attn: Data Protection Officer, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808or at dataprotectionofficer@sourceability.com. You are also free at any time to request that Sourceability stop using your personal information for marketing purposes by contacting us at Sourceability, Sourceability, Attn: Data Protection Officer, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808 or at dataprotectionofficer@sourceability.com.

Sourceability North America LLC, a Delaware limited liability company with its registered office address at 2711 Centerville Road, Suite 400, City of Wilmington, Delaware 19808(“Sourceability”) owns and operates the Sourceability 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.