Operative Privacy Policy

Introduction

Operative (SintecMedia Ltd. d/b/a Operative, SintecMedia NYC, Inc. d/b/a Operative, and our affiliates and subsidiaries) (“Operative,” “we,” “us,” “our,” or the “Company”) is committed to protecting your privacy. This Privacy Policy applies to Operative’s Website (www.operative.com), and Operative’s related services and applications (the “Services”). This Privacy Policy describes your options regarding use, access and correction of your personal information, as well as your options for opting out of certain uses of your personal information. By using the Website you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not use the Website.

1. Important Information

1.1 Changes to this Privacy Policy

We may revise this Privacy Policy from time to time. You should visit this page periodically to review our current Privacy Policy so that you will always know what information we gather and how we may use that information. Your continued use of the Website will be subject to the terms of the then-current Privacy Policy.

1.2 Managing your information

Should you have any questions in regards to this Privacy Policy or would like to receive information about your personal information we store, or opt-out of certain uses of your personal information, or exercise any of your individual rights under the GDPR (as defined hereunder, if applicable), please contact us at the following email address: privacy@operative.com.

In addition, any marketing communications we send to you will include a link or other method to quickly and easily unsubscribe and decline further similar communications.

1.3 Personal Information

Personal information is generally information that can identify an individual or information about an identifiable individual, or any other definition set forth in an applicable legislation. Personal information includes contact information, such as your name, e-mail address, address, phone number, and other information about yourself.  “Personal Data” shall have the meaning ascribed to it under the GDPR.

1.4 General Data Protection Regulation (“GDPR”)

Means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data (as defined in the GDPR) and on the free movement of such data. The individual rights of EU citizens under the GDPR include the right of access to Personal Data, right to rectification or Personal Data, right of erasure of Personal Data, right to restrict/suspend processing of Personal Data, right to complain to a supervisory authority, as well as additional rights that may apply in certain instances: The right of data portability, right to withdraw consent, right to object to processing and the right to object to processing of Personal Data for direct marketing purposes.

2. Information we Collect

2.1 Operative Website

When you sign up for our newsletter or express an interest in receiving additional information about the services, you are required to provide Operative with personal contact information, such as name, company name, address, phone number, and email address (“Contact Information”).

When you apply for a job with Operative via the Website, you may be requested to provide your Contact Information and submit additional personal information such as your curriculum vitae.

When you browse our Website, we may automatically collect certain information such as Cookies and other similar technologies such as web beacons. Cookies refer to a capability built into all browsers that allow a website to store data on a visitor’s computer for future use. Such data includes standard information from your web browser, such as browser type, browser language and your IP address. Security features built into all browsers prevent this data from being shared across different websites, so a website can only access information that it already had knowledge of and previously stored. Web beacons are small pieces of code placed on web pages that can be used to determine certain metrics about the Website, such as counting the visits of each page.

2.2 Operative Services

We collect customer information directly from our customers. For example, we will collect customers’ contact information such as name, address, phone number, and email address. In addition, we may process any information that a customer may choose to provide us via the Services, including personal information.

3. How We Use Information We Collect

We use the information we collect for the following purposes:

  • To perform the services requested. For example, if you sign up to our newsletter we use the Contact Information you provided us with in order to send you the newsletter. We may also use your Contact Information to send you information about Operative’s products or Services
  • To provide Operative’s Services which you subscribed to. In that respect, when a customer chooses to provide us with personal information via the Services, Operative will process that data in accordance with the Customer’s instructions and applicable law
  • To communicate with you as needed, whether by telephone, email or mail
  • Personal information collected while you browse our Website is used to monitor and improve the experience of our Website.

For the avoidance of doubt, we will never sell your personal information to any third party and we will never use your personal information for any other purpose other than the purpose for which the personal information was provided.

4. Sharing of Information Collected

We may share the information we collect via Operative’s Website as follows:

  • With our affiliates and subsidiaries, which include entities controlling, controlled by, or under common control with Operative;
  • With vendors, service providers, agents, contractors, or others (collectively “Service Providers”) who perform functions for Operative or on our behalf. For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, marketing and promotions.  We provide our Service Providers only with the information necessary for them to properly perform the requested services.
  • As necessary to comply with applicable legal obligations, including requests from law enforcement or other governmental entities.
  • If Operative is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may share or transfer Personal Information in connection with such transaction.

5. Security of your Personal Information

Operative recognizes the importance of safeguarding the confidentiality of your personal information. Accordingly, we use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. However, by providing us with personal information you acknowledge that no data transmission over the internet or other network can be guaranteed to be 100% secure. As a result, any personal information you provide to us is provided at your own risk.

6. International Transfer of Information

Operative has global operations. Therefore, we may transfer and access personal information from around the world, including the United States. This Privacy Policy shall apply even if we transfer personal information to other countries.

Notwithstanding, to the extent any Personal Data (as defined in the GDPR) of individuals based in the EU/EEA is provided by you or by a customer to any of Operative’s entities based in the EU and transferred to any of Operative’s entities outside the EU/EEA or to any other recipient outside the EU/EEA, Operative ensures the transfer is in full compliance with EU data protection laws by ensuring that an adequate level of protection is given to that Personal Information and that adequate technological and organizational safeguards are put in place to protect the Personal Information. As an example, all of Operative entities have entered into the EU model clauses with one another and we ensure that any service provider that process Personal Data (as defined in the GDPR) of EU/EEA individuals on Operative’s behalf adheres to one of the required methods for meeting the ‘adequate protection’ under EU data protection laws.

7. Providing Services to Customers located in the EU/EEA

For our customers located in the EU/EEA, Operative shall always be considered the “processor”, as defined in the GDPR and the customer shall always be considered the “controller”.

Consequently, if you, as our customer, are required under the GDPR or any applicable EU legislation to enter into a contract with your data processors, you are requested to contact your account manager and we will send you Operative’s Data Processing Addendum.

8. Data Retention

We retain personal information that you provide us for as long as required in accordance with the purpose for which the personal information was provided to us, or otherwise as required according to any applicable law or regulation.

9. Children

Our Website and Services are not intended to nor do they seek to receive information from children under the age of 13.