Privacy Policy

Introduction

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Sonocent respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use our website and software and tells you about your privacy rights and how the law protects you.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, last name, username or similar identifier.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, license key, computer system details, operating system and platform.

Usage Data includes information about how you use our website or software.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data where we need to collect personal data under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have, or, are trying to enter into with you (for example, accessing the software). In this case, we may have to cancel your use of our services and we will notify you if this is the case.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity and Contact data through forms by or by corresponding with us by phone email or otherwise. This includes personal data you provide when you:

• Create an account

• Give us feedback

• Request marketing communications to be sent to you

• Enter a promotion or survey

Automated technologies or interactions

As you interact with our software, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please refer to section 5 for our Cookie and Pixel policy.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we have gathered consent to do so.

• Where we need to perform the contract, we are about to enter into or have entered into with you. (e.g. registration details so we can ensure your account is protected).

• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

• You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data as part of using our website and software, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of activating or registering the software that are necessary for performing our contract with you.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Cookie and Pixel Policy

What are cookies and tracking pixels and what do they do?

Part of the personal data we collect is done so via cookies and tracking pixels, which are in part placed by third parties. Cookies and tracking pixels are small pieces of information that are placed on your computer when you visit certain websites. They collect or receive specific types of information and use this information to improve your experience and provide targeted advertisements. We use different types of cookies and pixels on the Glean website and Glean web application.

How we use cookies

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period of time until you delete them). We use the following types of cookies for the purposes explained in this chart:

Managing cookies

You can delete cookies stored on your computer and / or change your cookie settings at any time through your browser settings. For more information, please refer to the following links:

Internet Explorer

Microsoft Edge

Google Chrome

Mozilla Firefox

Safari

If you disable or refuse cookies, please note that some parts of the Glean website and Glean web application may become inaccessible or not function properly.

For information about how long data collected via third party cookies is retained, please see the privacy statement of the relevant third parties linked above.

Tracking pixels and how we use them

We and third parties make use of the following tracking pixels when you visit the Glean website or Glean web application:

What is remarketing?

Remarketing (also known as retargeting) means to serve targeted ads to people who have already visited or taken action on a website.

Do Not Track

Sonocent makes use of the Cookiebot cookie and related technologies consent management tool. This tool will honour DNT preferences. For more information about Do Not Track, please visit https://allaboutdnt.com/.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.

• External Third Parties as set out in the Glossary.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

We share your personal data within the Sonocent group. This will involve transferring your data outside the European Economic Area (EEA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules". For further details, see European Commission: Binding corporate rules.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

For further information, please refer to our Customer Data Security Policy.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.