Risk Based Security, Inc.
- Our company and websites
- Collection of personal identification information
- Lawful basis for processing personal identification information
- Storage of personal identification information
- Our security measures
- Your rights
- Contact us
At Risk Based Security, Inc. (RBS) we appreciate the trust you place in us when sharing your personal identification information. The security of that information is very important to us.
We have four principles:
- We do not ask for personal identification information unless we truly need it to communicate with you or provide you access to our products and services.
- We do not sell, trade, or rent your personal identification information to anyone.
- We do not share your personal identification information unless it is necessary for us to operate our business or administer activities in order to provide you with information that you requested or to provide you with access to our products and services or to comply with the law.
- We do not store personal identification information for any longer than necessary.
In this document, we will explain how we collect, use and protect your personal identification information. We will also explain what rights you have with regards to your personal identification information and how you can exercise those rights.
2. Our company and websites
RBS is a single USA based entity with no affiliates or subsidiaries. We are the controller of your personal identification information and determine what identification information is collected, how this identification information is going to be used and how this identification information is protected. Our websites are:
Unless otherwise specifically stated, we consider these websites to be US-based websites.
3. Collection of personal identification information
We collect personal identification information from you for one or more of the following purposes:
- To provide you with information that you have requested or which we think may be relevant to a subject in which you have demonstrated an interest;
- To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services;
- To fulfil a contract that we have entered into with you or with the entity that you represent;
- To ensure the security and safe operation of our websites and underlying business infrastructure, and
- To manage any communication between you and RBS.
The table in Section 4 below provides more detail about the type of identification information that we collect, the lawful basis for doing so, and how long we will retain your personal identification information.
In addition to the collection of personal information outlined above, we collect technical data from our website visitors. We do this in order to ensure that visitors to our websites can use and navigate each site effectively. We collect the following when you visit our sites:
- Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet;
- Your login information, browser type and version, time zone setting, browser plug-in types and versions;
- Operating system and platform;
- Information about your visit, including the Uniform Resource Locators (URL) clickstream to, through, and from our site.
In Section 7 below, we identify your rights with respect to the personal identification information that we collect from you and describe how you can exercise those rights.
4. Lawful basis for processing of personal identification information
The table below describes the various forms of personal identification information RBS collects and the basis for processing your identification information. We have processes in place to make sure that only those people in our organization who need to access your identification information can do so. Certain pieces of identification information, such as email addresses, are collected for multiple purposes. These are outlined in the below table.
Like nearly every modern business, RBS contracts with certain third party organizations in order to operate our business. These third party organizations provide RBS with services such as software development, customer relationship management software and email delivery. Some of your personal identification information may be processed by these organizations, but only under the direction and control of RBS. If you contract for certain services from RBS, your personal identification information may be shared with additional third parties in order to fulfill our agreement. Where this happens, it is also identified below.
When we process your personal identification information on the basis of legitimate interest, we apply the following test to determine whether processing is appropriate:
- The purpose test – is there a legitimate interest behind the processing?
- Necessity test – is the processing necessary for that purpose?
- Balancing test – is the legitimate interest overridden, or not, by your interests, rights or freedoms?
5. Storage of personal identification information
RBS is a USA-domiciled organization whose primary offices are in the USA.
- Our websites and web applications are hosted in the USA.
- The websites identified in section 2 above are accessed by staff located in both the USA and the EU. In all instances, we have appropriate contractual and security measures in place to ensure that personal identification information is protected.
- Our customer relationship management, marketing and accounting systems for all our businesses are USA-based.
- We use a wide range of Cloud Service Providers (CSPs) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
- Our banking arrangements are based in the USA.
- We operate a retention policy in respect of all confidential information, whether paper-based or digital and those aspects of it which relate to personal identification information are contained in the table above.
6. Our security measures
Our information security management system (ISMS) is based on the best practice security controls defined in ISO/IEC 27001. We have what we believe are the “Risk Based” appropriate security controls in place to protect personal identification information. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our ISMS. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
7. Your rights
You have certain rights with regard to your personal information. If you wish to exercise any of these rights, please email [email protected] or use the information supplied in the Contact us section below. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:
- The right to be informed
- The right of access
You may request a copy of the personal identification information we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal identification information we hold about you as well as the following information:
- The purposes of the processing
- The categories of personal identification information concerned
- The recipients to whom the personal identification information has been disclosed
- The retention period or envisioned retention period for that personal identification information
- When personal identification information has been collected from a third party, the source of the personal identification information
- If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or unreasonable expense (which you may have to meet), we will inform you.
- The right to rectification
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this personal identification information. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
- The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal identification information, you may request that we delete the personal identification information. This includes personal identification information that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
- The right to restrict processing
You may ask us to stop processing your personal identification information. We will still hold the identification information but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
- The accuracy of the personal identification information is contested
- Processing of the personal identification information is unlawful
- We no longer need the personal identification information for processing but the personal identification information is required for part of a legal process
- The right to object has been exercised and processing is restricted pending a decision on the status of the processing
- The right to identification information portability
You may request your set of personal identification information be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
- The right to object
You have the right to object to our processing of your identification information where
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of scientific or historic research;
- Processing involves automated decision-making and profiling.
8. Contact us
Alternatively, you can contact our Data Protection Officer at the following:
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.