Privacy notice

May 2018

This website is operated by Sardina Systems Ltd (“Sardina Systems”) of 7 Bell Yard, London WC2A 2JR, the UK also referred to in this Privacy Statement as “we” or “us”. Sardina Systems is a global Independent Software Vendor. Sardina Systems is committed to protecting and respecting your privacy. This notice describes how we will collect and use your information and the rights you have in relation to your information.

We may collect information from you about your preferences through your use of this website, when you request information from us or engage with our OpenStack software or other services, or as a result of your relationship with one or more of our partners.

By using any of our services, including this website, and by providing us with any personal information, you are consenting to the use of your personal information as set out in this Notice. Please do not send us any personal information if you do not want that information to be used in this way.

References in this notice to “your information” are also to personal information that you provide to us. Sardina Systems is the data controller of any information provided via this website and our contact details together with details of our registration with the UK Information Commissioner’s Office are set out below.

Sardina Systems is committed to complying with data protection laws applicable to its business, including the European Union’s General Data Protection Regulation (“GDPR”). We recognise that ensuring GDPR standards are embedded in our day to day operations where we handle Personal Data of EU citizens is a key GDPR compliance requirement.

Information we collect

Sardina Systems may ask for and collect any information which enables us to identify you and which is related to an identified or identifiable natural person (also known as a ‘data subject’), such as a name, an identification number, location data, an online identifier to one or more factors specific to the identity of that natural person.

In addition to the information you knowingly provide, Sardina Systems collects the domain names and IP addresses of its visitors, along with usage statistics (e.g., types of web browsers and operating systems used) and browsing history. This data is used to promote our services. Sardina Systems may combine this information with the personally identifiable and other information it collects.

How we use your information

At Sardina Systems collects and uses your personal data, and in the same time committes to protecting and respecting your privacy and will only use your personal information:

  • to provide you or the business with whom you are associated with certain personalised services;
  • to support activities such as customer service, marketing, product and service development, dissemination of investor information and recruiting;
  • to inform you or the business with whom you are associated of our products and services and provide you with our latest information and news about Sardina Systems Ltd;
  • to enable you to contact Sardina Systems Ltd and for us to respond to you;
  • to carry out from time to time certain newsletters about how Sardina Systems is doing; and
  • to analyse the use of this website by you in order to develop and enhance the services we may provide to the business with whom you are associated, and to facilitate subsequent use of this website.
Email marketing list and marketing messages

We operate an email mailing list program, used to inform you about products, services and/or news we supply/publish. You can change your preferences for receiving group marketing emails, product updates and other information from us at any time. You can unsubscribe at any time through an automated online service or, if this is not available, by the method referred to in the footer of sent marketing messages. Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.

Please note that we may use your marketing and content preferences, and other information you provide to us (including details of your attendance at, or interest in, events) in order to build a profile for you. We may supplement this profile with information about how you use our websites, review our content and interact with us. We use this profile to try and ensure that you only receive information that you are likely to find of interest.

Disclosure of information we collect

We will not disclose your Personal Data to anyone except as described in this Privacy Policy.

We may share your Personal Data with companies within Sardina Systems Ltd.

We may share Personal Data with our contracted service providers, vendors, suppliers and our third-party processors such as third-party marketing service providers acting on our behalf and under our instructions. These providers are authorized to use your Personal Data only as necessary to provide the services. Sardina Systems Ltd is focusing its efforts to ensure that they handle this Personal Data in light with the high standards of applicable data protection rules, including GDPR.

In the event that you opt in for receiving promotional materials, we may from time to time notify you of special promotions, new products or services, or other information that may interest you.

We reserve the right to disclose any such Personal Data if required to do so by law, or in the good faith belief that such action is reasonably necessary to comply with applicable law, or protect the rights, property or safety of Sardina Systems, its employees, customers, or the public.

Transfer of your personal data

Please note that we may on occasion be required to share your information with other Sardina Systems member firms, our own offices around the world and other third parties who provide services to us or on our behalf. This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA. The level of information protection in countries outside the EEA may be less than that offered within the EEA, however we have procedures in place to ensure the protection of your information. However, we have taken steps to ensure that all such entities keep your personal information confidential and secure and only use it for the purposes that we have specified and have informed you of. In relation to any other third parties we will only disclose your information where you have given your consent or where we are required to do so by law, or where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights.

Sardina Systems has in place all appropriate legitimization measures to ensure the validity of Personal Data transfers to countries in which there is not a similar level of protection as in your country and as required under applicable data protection and privacy laws. Those legitimization measure include the entry into appropriate inter-company data transfer agreements based on the European Standard Contractual Clauses (“EU Model Clauses”) and the implementation of Binding Corporate Rules as defined under European Union regulations.

User consent

By using this web site and other online portals, you consent to the to the practices described in this Privacy Policy and to our processing of your Personal Data for the purposes described above as well as those explained where Sardina Systems collects Personal Data on the web or in other online portals.

Where required, we will be supplementing this consent with a more specific statement at the time that we specifically obtain the Personal Data from you.

Should you wish to have your Personal Data removed, please let us know via info@sardinasystems.com.

Cookies

Some of our web pages may utilize “cookies” and other tracking technologies. A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information such as a user ID, which the site uses to track the pages you’ve visited, but the only Personal Data a cookie can contain is information you supply yourself. A cookie cannot read data off your hard disk or read cookie files created by other sites. Some parts of Sardina Systems’s web site use cookies to track user traffic patterns. We do this to determine the usefulness of Sardina Systems’s information to our users and to see how effective our navigational structure is in helping users reach that information. Sardina Systems does not correlate this information with Personal Data about individual users, nor does it share this information or sell it to any third party.

You may set most browsers to notify you if you receive a cookie or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the website.

Tracking technologies may record information such as Internet domain and host names, Internet protocol (IP) addresses, browser software and operating system types, clickstream patterns and dates and times that our site is accessed. Our use of cookies and other tracking technologies allows us to improve our website and your online experience. We may also analyze information that does not contain Personal Data for trends and statistics.

Confidentiality

We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make personal information commercially available to any third party, except that we may share information with our service providers for the purposes set out in this Privacy Notice. We will maintain the confidentiality of and protect your information in accordance with our Privacy Notice and all applicable laws.

How we protect information

Sardina Systems attempts to protect against the loss, misuse and alteration of your personal information.  Sardina Systems has implemented reasonable administrative, technical and physical measures to protect your personal information.

Your rights

Subject to applicable data protection rules, you are entitled to a right of access to Personal Data that Sardina Systems collects about you, a right of rectification and deletion and a right to restrict and object to the processing of your Personal Data on legitimate grounds. We also ensure that Sardina Systems has high level procedures in place to deal with any suspected breach of data security, unauthorized access or disclosure, or loss of Personal Data. We guarantee that your rights in the unlikely event of a data breach are fully respected.

You may choose whether or not to provide Personal Data to Sardina Systems. The notice we intend to provide where Sardina Systems collects Personal Data on the web site or on the applicable online portal should help you to make this choice. If you choose not to provide the Personal Data we request, you can still visit most of Sardina Systems’s web pages, but you may be unable to access certain options, offers and services that involve our continued interaction with you.

You should be aware that if you delete or restrict our access and use of certain Personal Data we use to provide contracted services to you or the business with whom you are associated, it may have an impact upon our ability to continue to provide those services to you or the business with whom you are associated.

If you do not want to receive information from us

If you receive marketing materials from us, you may withdraw your consent for us to send these to you at any time and free of charge by sending an e-mail to info@sardinasystems.com .

Changes to this privacy policy

Sardina Systems reserves the right to change the terms of its Privacy Policy at any time. If we do change this Privacy Policy, we will take steps to indicate that the Policy has been updated on this website. Sardina Systems will provide notification of the changes to this Privacy Policy through access to its website.

Contact information

If you have any questions in relation to this Privacy Policy, or if you would like to contact us to exercise your rights as stated in this Privacy Notice, you may contact us at info@sardinasystems.com .

Sardina Systems is registered under the Registrar of Companies in England and Wales with the company registration number 09689443.

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