Hazelcast respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our in-memory computing products, Hazelcast IMDG and Hazelcast Jet, as well as our websites Hazelcast.com, Hazelcast.org, Blog.Hazelcast.com and Jet.Hazelcast.org (“Sites”), and tell you about your privacy rights and how the law protects you.
- Who we are and how to contact us
- Your rights relating to your Personal Data
- Marketing communications preferences
- What Personal Data we collect
- How we use your Personal Data and why
- What happens when you do not provide necessary Personal Data?
- Personal Data from Third Party Sources
- Who we share your Personal Data with
- How we keep your Personal Data secure
- How long we store your Personal Data
- Our policy on children
- Third party links
Who we are and how to contact us
Who we are
Our address is: 350 Cambridge Avenue, #100, Palo Alto, CA, USA, 94306
How to contact us
You can contact us by emailing: firstname.lastname@example.org
Our EU Representative
Our EU representative is: UK Software Services and Consulting Ltd. Our EU representative may be contacted via email: email@example.com; via mail: Hazelcast, WeWork, 1 Fore Street, London EC2Y 9DT United Kingdom; or via phone: +44 20 3198 1655.
EU-U.S. PRIVACY SHIELD
As described in the Privacy Shield Principles, Hazelcast is accountable for Personal Data that it receives and subsequently transfers to third parties. If third parties that process Personal Data on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.
Hazelcast has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit www.jamsadr.com; JAMS, 18881 Von Karman Ave., Suite 350, Irvine, CA 92612, USA; Telephone +1 (949) 224-1810 for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Your rights relating to your Personal Data
By law you have the right to:
- Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation that makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us at firstname.lastname@example.org.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
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.
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.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
Marketing communications preferences
You can ask us to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you, by contacting us at any time using the contact details shown here “Who We Are and How to Contact Us”, and by visiting the Hazelcast Privacy Preference Manager.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of emails relating to purchases, service & support, specific future requests for collateral or other materials, and subscription renewals.
What Personal Data we collect
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
|Category of Personal Data collected||What this means|
|Identity Data||First name, surname, maiden name, last name, company name, title.|
|Contact Data||Work address, billing address, email address, and telephone numbers.|
|Transaction Data||Any details about payments and communications to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third parties.|
|Marketing and Communications Data||Your preferences in receiving marketing from us and our third parties and your communication preferences.|
|Behavioural Data||Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into “segments” (e.g., there may be a segment for developers, living in London).|
|Technical Data||Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.|
No Special Categories of Personal Data
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). We also do not collect any information about criminal convictions and offences.
How we use your Personal Data and why
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
||To register you as a new customer.||Contractual Necessity.|
|To process payments for subscriptions to the Products and Services.||
||To process and deliver your order including manage payments, fees and charges.||Contractual Necessity|
||To keep our website, our services and associated systems operational and secure.||
We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.
|Troubleshooting||Technical Data||To track issues that might be occurring on our systems.||
It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services.
||To determine what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.||
We have a legitimate interest in providing you with updates on our Sites and related offers where you have purchased or shown interest in similar services from us.
What happens when you do not provide necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to perform 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, to provide you with the functionalities of the Site).
In this case, we may have to stop you using our Site have with us but we will notify you if this is the case at the time.
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
|Third party data source||Publicly available?||Category(ies) or other types of personal data received.|
|Credit Reference agencies||No||
|Social Media sites||No||
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Sites.
We use two broad categories of cookies:
- First party cookies, served directly by us to your computer or mobile device; and
- Third party cookies, which are served by our partners or service providers on our Site.
Cookies we use
Our Sites use the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our Sites and to enable you to use some of its features. For example, cookies allow you to log in to secure areas of some of our Sites. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our Sites to remember choices you make when you use our Sites, such as remembering your language preferences, remembering your login details, remembering previously completed form data, and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences or contact information every time you visit our Sites.|
|Analytics and Performance Cookies||
These cookies are used to collect information about traffic to our Sites and how users use our Sites. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable” This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Sites. The information collected is aggregated and anonymous. It includes the number of visitors to our Sites, the websites that referred them to our Sites, the pages they visited on our Sites, what time of day they visited our Sites, whether they have visited our Sites before, and other similar information. We use this information to help operate our Sites more efficiently, to gather broad demographic information and to monitor the level of activity on our Sites.
We use Google Analytics for the above purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: developers.google.com/analytics/resources/concepts/gaConceptsCookies.
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
|Targeted and advertising cookies||These cookies track your browsing habits to enable us to show advertising that is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.|
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our Sites or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.|
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help,” “tools,” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognise your computer or mobile device and you may need to log in or re-enter your contact information every time you visit our Sites.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com/uk/.
In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
You can also prevent the use of Google Analytics relating to your use of our Sites by downloading and installing the browser plugin available via this link: tools.google.com/dlpage/gaoptout?hl=en-GB
Who we share your Personal Data with
The table below describes who we share your Personal Data with, what we share, and why we share it.
We share your Personal Data within Hazelcast, Inc. This will involve transferring your data outside the European Economic Area (“Europe”).
Many of our external third parties are based outside Europe, so their processing of your Personal Data will involve a transfer of data to countries based outside of Europe.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
- We may 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 service providers outside Europe, 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 service providers based in the U.S., 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 Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
|Recipients||Category(ies) of Personal Data we share.||Why we share it||Location(s)|
||Our affiliates help us provide our service and help manage our customer relationships (including providing customer support, customer liaison etc).||
||Our service providers provide us with IT and system administration services.||
||Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance, and accounting services.||
|HM Revenue & Customs, regulators and other authorities||
||Authorities may require reporting of processing activities in certain circumstances.||
How we keep your Personal Data secure
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above “How we use your Personal Data and why”, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
|Category of Personal Data||Retention period|
|Behavioural Data||For so long as retention is necessary to fulfill the Purposes/Use for which it is used (see “How we use your Personal Data and why”).|
|Marketing and Communications Data||For so long as you remain a customer of ours.|
|Contact Data||For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see “How we use your Personal Data and why”).|
Our policy on children
Our Sites are not intended for children below 16 and we do not knowingly collect data relating to such children.
Third party links
Hazelcast, Inc., 2018