Mitratech Holdings, Inc. and its subsidiaries (“Mitratech,” ”we,” “us,” “our”) have adopted consistent, globally valid data protection and data security standards for processing the sensitive data of its clients, partners, prospects, and employees in line with globally accepted principles. Mitratech holds responsibilities for protecting the privacy of sensitive data, including any personal information being maintained, against threats posed by unauthorized access or misuse. In addition, Mitratech respects individual privacy and shall handle all sensitive information with care.
本声明适用于Mitratech Holdings, Inc.以及相关公司及其员工，并涵盖以下内容：处理与客户、合作伙伴、Mitratech员工和潜在客户有关的敏感数据。这包括与潜在客户、供应商和股东有关的数据。
Customer: an entity who subscribes to or licenses software applications or services from Mitratech.
敏感数据 - 任何与某人有关的信息，该人可直接或间接参照某项标识符，如：姓名、身份证号码、位置数据、在线标识符或与该自然人的身体、生理、遗传、精神、经济、文化或社会身份有关的一项或多项具体因素，或揭示种族、民族血统、性取向、政治观点、宗教或哲学信仰、工会会员资格或涉及个人健康的信息。此外，这还包括任何属于知识产权或被认为是Mitratech、其客户或第三方机密的信息。
数据主体 - 个人数据被控制者或处理者处理的自然人
数据处理员 - 代表控制人处理个人数据的自然人或法人、公共当局、机构或其他机构
数据控制者 - 一个自然人或法人、公共当局、机构或其他机构，单独或与他人共同决定处理个人数据的目的和方式。
同意 - 任何自由给予的、具体的、知情的和不含糊的数据主体意愿的表示，他或她通过声明或明确的肯定行动，表示同意处理与他或她有关的个人数据。
网站： 在Mitratech网站上收集的信息通常包括公司名称、地点、访问时间和日期，以及访问时浏览的网页。此外，我们还收集了用于查找我们网站的搜索引擎和搜索词组的信息。我们还可能收集互联网服务提供商的名称和你的计算机操作系统。Mitratech的网站使用 "cookies"，即可以由在你的硬盘上放置cookie的域的网络服务器读取的小文本文件。用户可能需要注册才能使用我们网站上的某些功能。注册时，我们要求你提供你的姓名、职务、公司、电子邮件地址和电话号码。Mitratech的代表将与你联系以建立一个账户。届时，我们可能会要求你提供其他信息。
Google API: Mitratech’s use of information received from Google APIs will adhere to Google APIs Terms of Service at https://developers.google.com/terms, including the Limited Use requirements. For information received from Google APIs, Mitratech:
- Does not allow humans to read the user’s data unless Mitratech has obtained the user’s affirmative agreement to view specific messages, files, or other data.
- Does not use or transfer the data for serving ads, including retargeting, personalized, or interest-based advertising;
- Limits its use of data to providing or improving user-facing features that are prominent in the requesting application’s user interface. All other uses of the data are prohibited;
- Only transfers the data to others if necessary to provide or improve user-facing features that are prominent in the requesting application’s user interface.
As a policy, Mitratech uses sensitive information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Mitratech takes reasonable steps to ensure that sensitive information is relevant to its intended use, accurate, complete, and current.
应用： Using Mitratech’s Applications, information can be processed on an organization’s own computers or on computers hosted by Mitratech. In the latter case, Mitratech is an Application Service Provider (ASP), however, each client, as the collector, administrator, and user of sensitive information within applications, has primary responsibility for the privacy of that information. Mitratech, as an ASP, may collect application usage data for the purpose of product improvement and support. If Customer has licensed artificial intelligence, machine learning, or Optical Character Recognition (OCR) functionality from Mitratech, then by Customer using that functionality, Customer’s data will be processed by the Mitratech application licensed by the Customer; this processed data may include sensitive data or personally identifiable information if Customer puts such data into the parts of applications that use artificial intelligence, machine learning, or OCR.
Customers, Partners, and Prospects: Mitratech may collect information from Customers, Partners, and Prospects for the purposes of marketing, product support, and other appropriate channels. This collection does not take place within any applications licensed by a Customer from Mitratech. Mitratech takes reasonable steps to ensure that sensitive information is relevant to its intended use, accurate, complete, and current. Mitratech does not provide any of the information we collect to third parties other than to market our products and services.
转让给代理人： Mitratech will obtain assurances from their agents that they will safeguard sensitive information consistently with this statement. Examples of appropriate assurances that may be provided by agents include, but are not limited to: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Data Privacy Principles, being subject to the EU General Data Protection Regulation (Regulation (EU) 2016/679), or being subject to another European Commission adequacy finding. Where Mitratech becomes aware that an agent is using or disclosing sensitive information in a manner contrary to this statement, Mitratech will take reasonable steps to prevent or stop the use or disclosure. Mitratech may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
国际信息转让： Mitratech primarily stores data about clients and visitors to the Mitratech website in the United States. To facilitate Mitratech’s global operations, Mitratech may transfer and access such information from around the world, including from other countries in which Mitratech has operations, such as the United States, United Kingdom, countries within the European Union, Singapore and Australia. A list of the Mitratech’s global offices is available upon request. This statement shall apply even if Mitratech transfers data to other countries.
Mitratech will inform individuals about the type(s) of sensitive information it collects, the purposes for which it collects and uses sensitive information, and the types of non-agent third parties to which Mitratech discloses or may disclose information, and the choices and means, if any, Mitratech offers individuals for limiting the use and disclosure of their sensitive information. Notice will be provided in clear and conspicuous language before individuals are first asked to provide sensitive information to Mitratech, or as soon as practicable thereafter, and in any event before Mitratech uses or discloses the information for a purpose other than that for which it was originally collected. Notices may be provided electronically, such as by a pop-up or banner or via email.
Information that is no longer needed for its intended purpose shall be deleted in compliance with Mitratech’s existing archival guidelines. Per the EU General Data Protection Regulation, applicable sensitive information may not be collected in advance and stored for potential future purposes unless required under the law of the individual nation.
Mitratech has implemented industry standard security methods, technologies, and processes to safeguard sensitive information from unauthorized access and unlawful processing or disclosure, as well as accidental loss, modification, or destruction. All sensitive information is treated as confidential; any unauthorized collection, processing, or use of such data is prohibited. In the context of increasingly flexible company organization, it must be ensured that employees have access to sensitive data on a need-to-know basis only. The need-to-know principle means that employees may have access to sensitive information only as is appropriate for the type and scope of the task in question. This requires a careful breakdown and separation, as well as implementation, of roles and responsibilities.
加州隐私权利： Under California law, California residents may request, once a year, free of charge, certain information regarding our disclosure of personal information to third parties for direct marketing purposes.
Mitratech will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of sensitive information in accordance with the principles contained in this statement. European Union or Swiss individuals with inquiries or complaints regarding their personal information should first contact Mitratech at [email protected].
Pursuant to the California Consumer Privacy Act of 2018 (CCPA), California residents have specific rights regarding your personal information as described below in sections I through X.
本《加州居民隐私声明》是对本网站所载信息的补充。 隐私政策 of Mitratech and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA) and any terms defined in the CCPA and CPRA have the same meaning when used in this Notice.
只有在我们出于某种合法目的需要你的信息时，我们才会收集本隐私政策中 "我们收集的个人信息 "部分所描述的关于你的信息。Mitratech只有在以下情况下才会拥有你的信息：(a)你自己提供的信息，(b)Mitratech自动收集的信息，或(c)Mitratech从第三方获得的信息。
- Data on users’ interactions with applications licensed by a Customer from Mitratech in order to inform Mitratech’s product development (e.g. assessing whether a function is being used or if it can be removed from the product)
To view the information PC Legal Tools Inc., dba TrackerCorp (“Tracker”) collects please visit the following link: 追踪器收集的信息
To view the information INSZoom.com, Inc. (“INSZoom”) collects please visit the following link: INSZoom收集的信息
To view the information Acuity Management Solutions (“Acuity ELM”) collects please visit the following link: Acuity ELM收集的信息
To learn more about the sources from which we collect those categories of personal information, how we use personal information, and how we transmit personal information, see the How We Use Personal Information and the Transmission of Information sections in this 隐私政策.
We may disclose your personal information to a third party for a legitimate business purpose. When we disclose personal information for a legitimate business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Your Choice in Information Use
Opt out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such emails. However, you will continue to receive notices and essential transactional emails.
Disable cookies: You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
Optional information: You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.
IV. Your rights with respect to information we hold about you as a business
Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information’s source, purpose and period of processing, and the persons to whom the information is shared.
Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
Pursuant to the CCPA, consumers have specific rights regarding your personal information. You have the right to access your personal information and the right to request that Mitratech disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. You have the right to request that we delete your personal information that we have collected and retained, subject to certain exceptions. Mitratech may deny your deletion request if retaining the information is necessary for us or our service provider(s) to complete certain business purposes or to comply with legal obligations.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request. We endeavor to comply with a request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you, in writing, the reason for the delay. Any information we provide will only cover the 12-month period preceding the request’s receipt.
Our services are not directed to individuals under 18. Mitratech does not knowingly collect personal information from children who are under 18 years of age. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 18 years has provided personal information to us, please write to [email protected] 与细节，我们将采取必要的步骤，删除我们持有的关于该儿童的信息。
Mitratech Holdings, Inc.
电子邮件： [email protected]