Citisoft Privacy Policy and Notice

Last Updated: October 7, 2022

This Privacy Policy and Notice (this “Policy”) describes how Citisoft, Inc., Citisoft Inc. UK and its affiliated branch offices (collectively, “Citisoft,” “we” or “us”) collect, use, store, and share information about you when you use our website www.citisoft.com and dependent pages or otherwise interact with us as described below (collectively, the “Site”). We are committed to maintaining the privacy and security of your personal information in compliance with applicable laws. We collect and process your personal information fairly and lawfully and in order to carry out our lawful business activities.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Policy, and in some cases, we may provide you with additional notice (such as adding a statement to our Site or sending you an email notification). We encourage you to review the Privacy Policy whenever you use our Site or interact with us to stay informed about updates to our privacy practices.

California residents may access the separate Notice of Collection of Personal Information and Privacy Policy with information and rights required by the California Consumer Privacy Act (CCPA) on our website. United Kingdom residents may access the Notice of Rights Under the UK General Data Protection Regulation (GDPR) at the end of this policy.

Acceptance Of These Terms

By using the Site, you agree to accept the terms of this Policy. If you do not agree to this Policy, please do not use the Site. Your continued use of the Site following the posting of any changes to this Policy will be deemed your acceptance of those changes.

Collection Of Personal Information

We may collect and otherwise process personal information from you in various ways:

• when you voluntarily provide us with information;
• when you communicate with us concerning our Services;
• when you submit an application for employment;
• through automated means when you use our Site including through use of “cookies,” web beacons, pixels and other similar technologies that track your online activity, including your use of our Site; and
• through information provided by third party vendors who analyze your usage of our website, such as Google Analytics.

Personal Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you use our Site, sign up to receive our informational or marketing materials, blogs or newsletters, submit an inquiry, request customer support, upload documents or otherwise communicate with us. The types of information we may collect include your name, email address, job title and any other information that identifies you that you choose to provide.

When you submit an application for employment, we will collect (through our third party provider isolved Hire) your name, email, mailing address and telephone numbers for contacting you, and professional, educational and employment related information to consider you for employment.

Information We Collect Automatically

In addition to personal information you choose to provide us, we and our third-party service providers and advertisers may use a variety of technologies to automatically collect certain information whenever you visit or interact with the Site. This information may include information we automatically collect as you browse the Site, including browser type/identifier, your IP address, device type or client/user identifier, device advertising IDs, operating system, language settings, web pages and sections visited, amount of time spent on pages, keywords and searches used, referring and exit pages, and forms submitted

Cookies

We may use cookies and other tracking technologies to collect information about you when you interact with our Site, including information about your browsing behavior. Cookies are small text files sent by your computer or device each time you visit our Site, which are unique to your browser or device. Cookies make web surfing and browsing easier for you by saving your preferences so that we can use these to improve your next visit to our Site. We use first party cookies set by us, and services provided by third parties using third party cookies or tracking technology, to provide us with information concerning your website activity and to provide you with advertising. Third parties may use third party cookies to collect information and track your internet activity when you visit their websites or other websites for their own business purposes. Third party cookies, which are cookies from a domain different than the domain of the website you are visiting, are used for our advertising and marketing efforts.

Cookies help us learn which areas of our Site are useful and which areas need improvement. We may combine this information with other information we collect about you. We use this information for various purposes, such as improving our Site and your online experience, understanding which areas and features of our Site are popular, counting visits, understanding advertising effectiveness, tailoring our communications with you, marketing our Services to you and for other business purposes. Other cookies are necessary for the Site to function properly or enhance the Site’s performance, security and functionality.

We collect visitor permission for our use of cookies through a notice in the form of a cookies banner that appears on the Site that gives visitors the option to accept or decline the use of cookies. You can choose whether to accept cookies by changing the settings on your browser. Please consult your Internet browser’s documentation for information on how to do this. However, if you choose not to accept essential or functional cookies, the Site may not function properly and some features may not work as they were intended. When we use cookies or other similar technologies, we may set the cookies ourselves or ask third parties to do so to help us. For example, our web analytics provider (Google Analytics) may collect information on our behalf concerning your website usage through first party cookies. You can opt out of Google Analytics’ collection and use of data (cookies and IP address) by downloading and installing the Google Analytics Opt Out browser plug-in, available via Google’s website.

Cookies we use may be either persistent or temporary (or session) cookies. A persistent cookie retains user preferences for a particular website allowing those preferences to be used in future browsing sessions and remains valid until its set expiration date (unless deleted by the user before the expiry date). A temporary cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Tracking Technologies, such as Pixels, Tags, Beacons

We and our third party partners may use pixels, tags or beacons on the Site to count how many users visit certain pages or content, for analytics and metrics about your visits to the Site, and to serve you advertising.

Third Party Technology

We may use this automated collection of personal information to improve our marketing programs and content, and to target advertisements to you. We do not control and are not responsible for third party tracking technologies that may be used on our Site. Such third parties may serve you content based on tracking you across different websites. You consent to encountering third party tracking technologies when you use our Site.

Email Tracking

When you communicate with us by email, we may use email tracking tools to ensure you received our email, or to determine whether you have opened it or clicked on any links or attachments. By communicating with us using email, you consent to receiving emails using tracking tools.

Third Party Advertisers

Third party vendors, including Google Ads, use cookies and other technologies to serve ads based on your visits to the Site. Those third party cookies enable those advertisers to serve ads to our users based on previous visits to our Site and other sites on the Internet. These technologies are able to link your other Internet activity with our Site for purposes of providing you with advertising that you may be interested in. We have implemented advertising in connection with our Site, including:

• Google Ads Advertising
• LinkedIn

Users may opt-out of the use of certain third party cookies, including by visiting the Google Ad and Content Network privacy policy, available at https://policies.google.com/technologies/ads?hl=en-US, or through their browser settings. You can understand which third parties have currently enabled cookies for your browser or mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative’s website at http://optout.networkadvertising.org or the Digital Advertising Alliance’s website at http://optout.aboutads.info or, if you’re located in the European Union (“EU”), at http://www.youronlinechoices.eu from your browser. For more information on mobile device specific opt-out choices, please visit http://www.networkadvertising.org/mobile-choices from your mobile device.

The table below sets out which cookies we use and why.

The table below sets forth which tracking technologies we use and why.

Use Of Information

We may use information about you for various purposes, including to: (i) facilitate and improve your website experience; (ii) provide information on the Services you request; (iii) respond to your comments, questions and requests and provide customer service; (iv) communicate with you about our Services, and provide news and information we think will be of interest to you; (v) personalize your online experience and provide advertisements, content or features that match your interests; (vi) monitor and analyze trends, usage and activities on our Site; and (vii) carry out any other purpose for which the information was collected.

In connection with an application for employment, we will collect and process personal information that you provide to us or that we may obtain through employment agencies, background check agencies or your professional or educational references. This information includes contact information, such as name, email address, telephone number and other identifiers, professional or employment related information, and education information. We may also collect information concerning your protected characteristics if voluntarily provided by you. We will use your personal information and share it with third parties solely for purposes of considering your application for employment, and should you be hired, in connection with your employment.

Sharing of Information

We do not sell your personal information to third parties.

We may share information about you as follows: (i) with vendors, consultants and other service providers who need access to such information to perform services on our behalf, including but not limited to, web hosting platforms, Information Technology and software providers; (ii) with third parties, such as advertisers; (iii) in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process or as otherwise required by any applicable law, rule or regulation or to defend against legal claims; (iv) if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third party; (v) in connection with, or during negotiations of, any merger, sale of company assets, financing or transfer of all or a portion of our business to another company; or (vi) with your consent or at your direction. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. We require our service providers, who provide services on our behalf to maintain the privacy and security of your personal information. We may share your personal information with third party advertisers for marketing purposes.

How Long Do We Store Your Personal Information  

We do not retain your personal information for longer than is necessary to fulfill the business purpose for which the information is being collected or processed or in order to comply with our legal obligations. For the time period of retention of information collected by cookies, please see the links to information provided in the table above.

Your Information Choices and Control

Citisoft respects your requests to access and control your personal information, so we give you certain choices that you may exercise, including:

• You may correct, update, and delete your information.
• You may change your choices for informational materials.
• You may request access to the personal information we hold about you and that we amend or delete it.
  Please note that we may deny your requests, including to change or delete information under certain circumstances. For example, we may be required by certain obligations to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database and systems, but there may be circumstances where it may remain in our archives or backup systems. We may also retain your information because of legal or contractual requirements or similar purposes.
• You can make requests concerning your personal information and choose to opt in or out of informational services and communications by contacting us at na.info@citisoft.com, calling us at +1 (617) 428 9580 or following the instructions directly provided in the communications we send you. You can opt out from receiving future marketing communications from as at any time by: (i) using the unsubscribe function in the email or marketing information you receive from us; or (ii) contacting us as at insights@citisoft.com.

Links To Third Party Websites

The Site may contain links to other websites. This Policy does not apply to the practices of other websites and Citisoft is not responsible for the actions and privacy policies of third parties. We encourage you to be aware of when you leave the Site and to read the privacy policies of each website that you visit.

How We Safeguard Your Personal Information

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.  We use reasonable administrative, technical and physical safeguards to secure data in our possession. While we strive to take reasonable protections to safeguard personal information, we cannot ensure or warrant the security of any information you transmit to us.

Site Users Outside the United States

By visiting the Site and providing us with data as a non-U.S. user, you acknowledge and agree that your personal data may be processed for the purposes identified in this Policy. We are based in the United States. By accessing or using the Site or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.

Children

We do not knowingly collect any personal information from children under the age of 16. We do not sell Services for purchase by children. If you are under 16 years old, please do not provide your information on the Site. If we become aware that an individual is under the age of 16 and has submitted any information to Citisoft for any purpose, we will delete his or her information from our files.  If you believe that we might have any personal information from a child under 16, please contact us at na.info@citisoft.com.

Do Not Track (DNT)

Your browser may allow you to send “do-not-track” requests to websites you visit. We do not presently respond to Do Not Track requests.

Notice of rights under the UK GDPR

Lawful Basis for Processing

Citisoft is committed to processing personal data only when there is a lawful basis under applicable law including:

• you have given consent to the processing of your personal data for one or more specific purposes (e.g., when you sign up to receive our marketing materials);
• processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
• processing is necessary for a legal obligation to which Citisoft is subject;
• processing is necessary in order to protect your vital interests or of another natural person; and
• processing is necessary for the purposes of the legitimate interests pursued by Citisoft or by a third party, except where such interests are overridden by the fundamental rights and freedoms of you or another individual which require 
  protection of personal data.
• we do not request that you provide special category personal data, such as sensitive information concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation. If you elect to provide us with such data, we will process it in accordance with your express consent to the processing for one or more specified purpose or where permitted by applicable law.

If you reside in the United Kingdom, or other countries in the European Economic Area (EEA), you may have the following data protection rights:

• Access: right to access your personal data and request certain information concerning your personal data, such as an explanation of the purpose of the processing and disclosure of third parties with whom Citisoft shares the data;
• Rectification: right to rectify inaccuracies in your personal data or to ensure that it remains up to date. Citisoft is committed to ensuring that your information is accurate and kept up to date. Please inform us of any changes to your personal data;
• Erasure: right to erasure of your personal data under certain circumstances. For example, you may request erasure if the data is no longer needed in connection with the reasons it was collected or processed or if you withdraw your consent to further processing. Citisoft may deny your request where it is required or permitted by law to retain your personal data or when we need to retain your information in connection with the exercise or defense of legal claims;
• Restriction: right to restrict processing where you contest the accuracy of the data in order to permit time to rectify the inaccuracies and in other circumstances;
• Data Portability: right to data portability by requesting a copy be provided in a structured, commonly used and machine-readable format and/or requesting that Citisoft transmit your personal data to a third party where technically feasible;
• Objection: right to object to processing of your personal data where you contest that the processing is necessary for the purposes of Citisoft’s legitimate interests. Citisoft may deny your request because it has compelling legitimate business interests or the exercise or defense of legal claims;
• Complaint: right to bring a complaint before the applicable governmental privacy regulator.

Residents of the EEA have the right to complain to a data protection authority about the collection and use of personal data. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available via the European Commission’s website.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.

Contact Us

If you have any questions about this Privacy Policy, the practices of the Site, your dealings with the Site, or to make a request concerning your personal information, please contact us: (i) by mail at 303 Congress St., 5th Floor, Boston, MA 02210; or (ii) by email at na.info@citisoft.com. You may also telephone us at+1 (617) 428-9580.