Showpad Privacy Principles (Last update 23 January 2020)
Showpad NV / Showpad inc. (“Showpad”) operate, exploit and maintain certain SaaS Products and Services (“Products and Services”) for and on behalf of Showpad customers’ use and benefit.
These Showpad Privacy Principles wish to explain what processing activities are taking place in respect of information relating to individuals (as being an identified or identifiable natural person) (“Personal Data”) when such individual (the “Data Subject”) is interacting, directly or indirectly (e.g. through an integration or through a software client), with the Products and Services and/or certain content of the Showpad Customer managed thereon (see FAQ B7.).
Showpad may change these Privacy Principles at any time, and all such changes are effective immediately upon posting a revised version of these Privacy Principles on the Showpad website. You should review these Privacy Principles often to stay informed of changes that may affect You. Your Interactions constitute Your continuing agreement to these Privacy Principles, as they are amended from time to time.
As GDPR currently is the most advanced and elaborate data protection legislation in the world, Showpad uses GDPR as its main benchmark for its companywide privacy program.
Seeing the global activities of Showpad, it goes without saying that with these Privacy Principles, in addition to GDPR, also want to take into account the principles of other applicable data protection legislations (such as the California Consumer Privacy act of 2018, the UK Data Protection act 2018, or, the Swiss Data Protection act).
The principles of such other data protection legislations have either already been incorporated through GDPR (in most of the cases) or either have specifically been added to these Privacy Principles.
Showpad is acting as “Processor” / “Service Provider” in respect of the operation of the Products and Services and not as data controller (see FAQ B12), which means that the Customer Policy shall always have priority over these Privacy Principles.
In no way do these Privacy Principles or the publication thereof mean that Showpad is taking up a role as data “Controller” under these Privacy Principles or taking up additional liabilities or responsibilities than as legally applicable between a controller and processor.
The publication of, or getting acceptance against, the Customer Policy (or absence thereof) occurs solely under the responsibility of the Showpad Customer.
Where the Data Subject already has accepted the Customer Policy (or where such (updated) Customer Policy subsequently becomes applicable) that cover Your interaction, directly or indirectly (e.g. through an integration or through a software client), with the Products and Services and/or certain Customer Content managed thereon, the Customer Policy shall apply instead of these Privacy Principles.
These Privacy Principles are being provided under the responsibility of the Showpad Customer, who is acting as data “Controller” for the processing activities covered under these Privacy Principles (see FAQ B12).
B. Showpad organistion
Organisational initiatives include: Dedicated privacy website & FAQ’s in respect of the Showpad privacy program: www.showpad.com/gdpr-information-hub/ and www.showpad.com/gdpr Data protection officer (DPO): Showpad has appointed a qualified data protection officer who supervises the entire data privacy program at Showpad and works in close conjunction with the Showpad Information Security Manager. The data protection officer is registered with the Belgian Data Protection Authority (https://www.dataprotectionauthority.be/). Vetting by Showpad of its vendors & subprocessors: Each vendor to Showpad is vetted by Legal, Infosec and the Showpad DPO in the areas of security, contractual terms and privacy related matters (e.g. data processing agreements, and applicable transfer mechanisms (e.g. EU standard contractual clauses / Privacy Shield)). Special attention is given to subprocessor that are acting as subprocessor with regard to the Products and Services. Contractual documents / privacy policies: Our contractual documents are state-of–the-art and contain the necessary provisions, including in respect of data processing agreements, end-to-end confidentiality, and privacy policies (meeting all necessary legal requirements). Privacy Shield certification: Showpad Inc. adheres to the EU-US Privacy shield, in order to facilitate and safeguard transfer of Personal Data to the US. ISO 27001 certification: The Products and Services are covered under the Showpad ISO 27001 certification Information security Management system (ISMS): Showpad has implemented an elaborate ISMS managing and following up on internal policies on data security.
Product related initiatives include: EU Data centres / US CDN opt out: Showpad’s principle hosting infrastructure is located within the EU at a first-class world-renowned hosting partner (AWS – 2 separate EU regions). CDN (Content delivery network) towards the Showpad US data centres can be switched off (AWS – US East region). Product engineering: All new product capabilities that are to be introduced within the Products and Services are vetted and checked for privacy compliance and follow three key cornerstones: (i) the GDPR principles of “privacy by design” and “privacy by default”, (ii) giving flexibility to both EU customers and non-EU customers to allow for localized application of the Products and Services – while (iii) keeping all changes as simple as possible. Elaborate privacy settings: The Products and Services provide for elaborate privacy settings allowing e.g. for a localized approach in a granular way or enabling/disabling tracking options. Self-Service Data Protection Agreement (DPA): To the extent the activities of the Showpad customer are covered by the material and territorial scope of an applicable data protection legislation (e.g. GDPR, CCPA, UK Data Protection Act, Swiss Data Protection act), such applicable data protection legislation may require that the processing of the personal data by the Showpad Products and Services is covered under a data processing agreement concluded between Showpad and its Customer. Showpad thereto makes available a complete DPA for self-execution via showpad.com/dpa that reflects the unique aspects of the Products and Services and containing all required specifics in order for the Showpad Customer to meet his legal obligations. 2. What security measures are used for the Products and Services? Showpad has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (a) the pseudonymisation and encryption of personal data; (b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; (c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
Showpad shall thereto take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.
While Showpad aims to implement industry-leading safeguards designed to protect Personal Data, we cannot guarantee that any Personal Data which was incidentally processed by the Showpad Customer (e.g. regulated or sensitive Personal Data, see FAQ’s B4 and B5) is maintained at levels of protection to meet specific needs or obligations the Showpad Customer may have relating to that type information.
The Showpad Information security program is covered under an ISO 27001 certification (see https://www.bsigroup.com/en-GB/our-services/certification/certificate-and-client-directory/), BSI certificate n° IS653767), as well as an ISAE3402 accreditation, and is audited on a regular basis by an external audit firm.
The Showpad Information security program is managed by the Showpad Information Security Team.
Showpad thereto makes available a complete DPA for self-execution via showpad.com/dpa that reflects the unique aspects of the Products and Services and containing all specifics – as required per the applicable data protection law – in order for the Showpad Customer to meet his legal obligations (e.g. standard contractual clauses).
Vie the URL www.showpad.com/dpa, you can access the e-signature platform where Showpad makes the DPA available for your review and possible execution.
A Cookies/Embedded script/Web Beacons does not contain or collect information in isolation, but when read by a server via Your web browser or through the Products and Services, it can provide information to such server (e.g. to facilitate a more user-friendly service by registering users’ preferences, detect errors, account information, device identification, statistical data, …).
The SHOWPAD_SESSION cookie in the Prospect microsite environment, is optional and placing this cookie on an end user Device is dependent on i) the applicable privacy settings as determined by the administrator of the Showpad platform at our customers, and ii) the corresponding consent given (or not) by the Prospect in question to become subject to the profiling towards the Customer Content shared. If consent was provided, this cookie will be placed and has a validity period of 14 days, after which consent will be asked again to confirm continued tracking. Deleting this cookie restricts further processing of Personal Data of the Prospect in question.
Deleting or disabling a Cookie can be done by using the following options:
Web browser Most web browsers (e.g. Internet Explorer, Mozilla Firefox, Safari, and Google Chrome) have cookies automatically enabled. You can decide on whether and to what extent cookies will access Your end device by changing your browser settings.
Tools Certain tools (e.g. “Ghostery”, “Disconnect”, … ) may provide you with more granular options in order to manage cookies.
F. Rights of Data Subjects
Obtain access to and/or rectification of one’s Personal Data as processed by the Products and Services; Request to receive one’s Personal Data in a format at the discretion of the Showpad Customer (e.g. excel, .CSV file, via the Showpad API, …), that allows for the data portability of such data to a similar service; Withdraw one’s consent for processing of one’s Personal Data (be advised that such leaves unharmed and does not affect the prior lawful processing of one’s Personal Data, or the continuation of processing of (part of) Your Personal Data as allowed under an applicable legal ground (see FAQ B15) The restriction of processing of Your Personal Data under article 18 GDPR and/or right to object to the processing of Your Personal Data under article 21 GDPR. Please check the applicable data protection legislation for the ability to exercise such rights.
As Showpad is merely the data “Processor” (see FAQ B12) such rights need to be exercised towards the Showpad Customer, as being the data “Controller”. In order to exercise such rights, You may be required by the Showpad Customer to provide proof of Your identity by providing an official document (e.g. ID Card, driver’s license, …).
Should Showpad receive such request directly from You, Showpad can legally only pass such request on to the Showpad Customer. Showpad is legally not allowed to respond to such request, unless as instructed by the Showpad Customer.
From the moment it is established that the Data Subject request is related to a processing activity for which the Showpad Customer is data “Controller”, and to the extent the Showpad Customer is identified, Showpad shall pass on such request without undue delay to the respective Showpad Customer, in order for the Showpad Customer to respond to such request.
If You have an unresolved complaint, You always have the right to log a complaint with the competent “data protection authority”. Information on the competent data protection authority and the way of logging a complaint can be found here (or the URL as updated by the European Commission).
Showpad NV, located in Belgium, acts as so-called:
“main establishment” in the EEA under GDPR. “representative“ in line with section 27 GDPR for and on behalf of Showpad Inc. As a result, the competent Data Protection Authority for Showpad NV is the Belgian DPA (Drukpersstraat 35, 1000 Brussel / +32 (0)2 274 48 00 / firstname.lastname@example.org / https://www.dataprotectionauthority.be/).
Showpad has appointed a data protection officer for the whole Showpad Group who can be contacted at “Office of the Data Protection Officer – Showpad NV – Moutstraat 62 – 9000 Gent (Belgium)” or email@example.com.
E. EU–US Privacy Shield
On July 12, 2016, the European Commission, through the “Commission implementing decision (EU) 2016/1250”, has accepted that the EU-U.S. Privacy Shield ensures an adequate level of protection for Personal Data transferred from the EEA to organisations in the United States, to the extent covered under the EU-U.S. Privacy Shield. To learn more about the Privacy Shield program, please see https://www.privacyshield.gov/Program-Overview.
Until further notice, the EU-U.S. Privacy Shield is deemed adequate to provide safeguards for transfers taking place from the UK towards a US Recipient, please see https://www.privacyshield.gov/article?id=Privacy-Shield-and-the-UK-FAQs
Showpad Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles, resulting in the fact that personal data originating from within the EEA as well as the United Kingdom may legally be exported to Showpad Inc. under this basis.
If there is any conflict between the terms in these Privacy Principles and the EU-U.S. Privacy Shield Framework, the EU-U.S. Privacy Shield Framework shall govern.
For purposes of enforcing compliance with the EU-U.S. Privacy Shield, Showpad Inc. is subject to the investigatory and enforcement authority of the US Federal Trade Commission.
To learn more about the Privacy Shield program, and to view the Showpad Inc. certification, please visit https://www.privacyshield.gov.
Transfer to third parties Where Showpad Inc., has received Your Personal Data in the United States and subsequently transfers that information to a third-party recipient (e.g. a subprocessor), and such third-party recipient processes Your personal data in a manner inconsistent with the Privacy Shield Principles, Showpad Inc. may be responsible under the Privacy Shield Principles to the extent Showpad Inc. is responsible for the event giving rise to the damage.
Binding arbitration You may also have the option to select binding arbitration for the resolution of Your complaint under certain circumstances. To find out more about the Privacy Shield’s binding arbitration scheme please see https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Please note that this policy applies only to our website and not to the web sites of other organisations to which we may provide links. We are not responsible for the privacy policies or practices of such third party sites and you should make your own enquiries in respect of them.
The types of Personal Data that this Website collects, by itself or through third parties, includes: name; email address; IP address; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example);
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide us with the Data.
The Data is processed at our operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. In certain circumstances, we may transfer your personal information to countries outside the European Economic Area. This may include circumstances where we use service providers who are based outside the EEA or who use “cloud” infrastructure which means that their servers are based all over the world. Where we transfer your information to companies outside the EEA, we will make sure it’s protected in a manner that is consistent with how your information will be protected by us. This can be done in a number of different ways for instance:
In other circumstances the law may permit us to otherwise transfer your information outside the EEA. In all cases however, we will ensure that any transfer of your information is compliant with the Data Protection Legislation.
Your Personal Data is collected to allow us to provide Services, as well as for the following purposes: User database management, Analytics, Advertising, Remarketing and behavioural targeting, Contacting the User, Content commenting, Displaying content from external platforms, Handling payments, Hosting and backend infrastructure, Access to third-party accounts, Tag Management and Productivity.
We may also process your Personal Data:
We may share your personal information with third parties but only in the circumstances set out below. We may supply your personal information to third parties (such as our internet service providers) who help us administer our website. These third parties must at all times provide the same levels of security for your personal information as heysummit.com and, where required, are bound by a legal agreement to keep your personal information private, secure and to process it only on the specific instructions of heysummit.com. Other third parties whom we may share your personal information with and the purposes this is for are listed below. Please refer to these third parties’ own privacy policies to find out more about how they might process your personal information.
FACEBOOK AUDIENCE NETWORK (FACEBOOK, INC.) Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.
This Website may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.
Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones.
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
FACEBOOK ADS CONVERSION TRACKING (FACEBOOK PIXEL) (FACEBOOK, INC.) Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
TWITTER ADS CONVERSION TRACKING (TWITTER, INC.) Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this Website.
LINKEDIN CONVERSION TRACKING (LINKEDIN CORPORATION) LinkedIn conversion tracking is an analytics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Website.
GOOGLE ANALYTICS (GOOGLE LLC) Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
GOOGLE ADS CONVERSION TRACKING (GOOGLE LLC) Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on this Website.
HEAP ANALYTICS (HEAP INC.) Heap Analytics is an analytics service provided by Heap Inc.
HUBSPOT (HUBSPOT, INC) HubSpot is a live chat, analytics, and marketing service provided by HubSpot Inc.
Content commenting services allow Users to make and publish their comments on the contents of this Website. Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
DISQUS (DISQUS) Disqus is a content commenting service provided by Big Heads Labs Inc.
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
FONT AWESOME (FONTICONS, INC. ) Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows this Website to incorporate content of this kind on its pages.
FONTS.COM WEB FONTS (MONOTYPE IMAGING INC.) Fonts.com Web Fonts is a typeface visualization service provided by Monotype Imaging Inc. that allows this Website to incorporate content of this kind on its pages.
GOOGLE FONTS (GOOGLE LLC) Google Fonts is a typeface visualisation service provided by Google LLC that allows this Website to incorporate content of this kind on its pages.
Payment processing services enable this Website to process payments by credit card, bank transfer or other means. To ensure greater security, this Website shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
STRIPE (STRIPE INC) Stripe is a payment service provided by Stripe Inc.
CHARGEBEE Chargebee is a payment management provider that is provided by Chargebee Ltd.
PAYPAL Paypal is a payment service provided by Paypal Holdings Inc.
This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data is stored.
AMAZON WEB SERVICES (AWS) (AMAZON WEB SERVICES, INC.) Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
FACEBOOK REMARKETING (FACEBOOK, INC.) Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
TWITTER REMARKETING (TWITTER, INC.) Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Website with the Twitter advertising network.
TWITTER TAILORED AUDIENCES (TWITTER, INC.) Twitter Tailored Audiences is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Website with the Twitter advertising network. Users can opt out from interest-based ads by going to: Personalization and Data.
LINKEDIN WEBSITE RETARGETING (LINKEDIN CORPORATION) LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Website with the LinkedIn advertising network. Remarketing and behavioural targeting
ZOOM.US Zoom.us is a webinar provider and is one of the available options for delivering summit content within HeySummit.
BIG MARKER Big Marker is a webinar provider and is one of the available options for delivering summit content within HeySummit. It is provided by BigMarker.com LLC
LiveWebinar is a webinar provider and is one of the available options for delivering summit content within HeySummit. It is provided by RTCLab Sp. z o.o. with its registered address at Al. Grunwaldzka 212, 80-266 Gdańsk, Poland
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
GOOGLE TAG MANAGER (GOOGLE LLC) Google Tag Manager is a tag management service provided by Google LLC.
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.
HELPSCOUT Help Scout PBC is a help desk software company headquartered in Boston, Massachusetts. It is used to facilitate customer support via email.
WIX ANSWERS Wix Answers is a help desk software from Wix.com company headquartered at 40 Namal Tel Aviv St., Tel Aviv 6350671, Israel. It is used to facilitate customer support via email.
We may also supply your personal information to government bodies and law enforcement agencies but only: if we are required to do so by the requirements of any applicable law; if in our good faith judgement, such action is reasonably necessary to comply with legal process; to respond to any legal claims or actions; or to protect the rights heysummit.com , its customers and the public.
We may process Personal Data relating to Users if one of the following applies:
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
We may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
We are committed to protecting the privacy of your Personal Data. We use appropriate standards of technology and operational security to protect personal information including a secure server and network firewall connection. Operationally, access to Personal Data is restricted to authorised personnel who are under a duty to maintain the confidentiality and security of such information. Internet and Data Storage
The Internet is inherently insecure. Personal Data submitted by means of the Internet may be vulnerable to unauthorised access by third parties. Submission of personal information using the Internet is at your own risk. We will take reasonable and appropriate technical measures to ensure that your Personal Data is stored in a secure manner. However, we shall have no liability for disclosure of data due to errors in transmission or the fraudulent, negligent or other illegal acts of a third party, such as ‘Hacking’. Any transmission of Personal Data on or through the use of our website is at your own risk.
Users may exercise certain rights regarding their Data which we process. In particular, Users have the right to do the following:
Where the Personal Data in question has been disclosed to a third party, we will inform them about the restriction on processing of the data, unless it is impossible or involves disproportionate effort to do so.
We may use the User's Personal Data may be used for legal purposes in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that we may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from us at any time. Please see the contact information at the end of this document.
This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, we shall collect new consent from the User, where required.
Hey Summit Ltd 71–75 Shelton Street Covent Garden London WC2H 9JQ