SessionForward considers data protection and privacy to be of paramount importance. We never sell personal data and we carry out all processing operations in strict compliance with the EU General Data Protection Regulation (“GDPR”)(specifically but not limited to Article 6(1)(b) to (f) and Article 28) as well as the Laws of Georgia, where SessionForward is incorporated, and other applicable global privacy and data protection laws such as the California Consumer Privacy Act (“CCPA”) (collectively, the “Applicable Law”).
Responsibility for Processing Personal Data
SessionForward bears responsibility for lawfully processing your data as carried out on our site.
What kind of Personal Data is processed and for what purpose?
When you visit our site we store the name of your internet service provider, the website from which you visited us from, the parts of our site you visit, the date and duration of your visit, and information from the device (device type, operating system, screen resolution, language, country you are located in, and web browser type) you used during your visit. While we process your IP address during the duration of your session, the IP address is truncated and thereby de-identified before it is ever written to disk on our servers. This is done by removing the last octet of your full IP address.
We process this usage data to facilitate your access to our services (e.g. to adjust our services to the device you are using), and to recognize and stop any misuse which is in our legitimate interest. The legal basis for this data processing is Article 6(1)(f) GDPR. We also process usage data in an aggregated or de-identified form for statistical purposes and to improve our site.
Cookies are stored on your individual device and you have full control over their use. You may deactivate or restrict the transmission of cookies by changing the settings of your web browser. Cookies that are already stored may be deleted at any time. Should you visit SessionForward’s site with cookies deactivated, you may possibly not be able to use all of the functions on our site to the full extent.
We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout.
Contact with us via email
On our site you have the opportunity to contact us to ask us questions, for example via the contact form, we ask you for your contact information (e.g. name, email address etc.). We use this data solely in connection with answering the queries we receive.
If you receive emails from us, we may use certain analytics tools, to capture data such as when you open our email or click on any links or banners our email contains. This data helps us to gauge the effectiveness of our communications and marketing campaigns.
You may deactivate your SessionForward account and/or unsubscribe from receiving content or offers from us at any time. Following termination of your account, we may retain your personal data (in part or in whole) in order to meet any regulatory and reporting requirements for the timeframes stipulated by law and in order to be able to address customer service issues. Any other personal data we would have been processing on your behalf would be deleted permanently within 30 calendar days.
Access and Disclosure to Third Parties
SessionForward does not sell, and has not sold, consumers’ Personal Data at any time. Except as provided below, we also do not share or disclose your Personal Data.
We use a select number of trusted external service providers for certain technical data analysis, processing and/or storage offerings. These service providers are carefully selected and meet high data protection and security standards. We only share information with them that is required for the services offered and we contractually bind them to keep any information we share with them as confidential and to process Personal Data only according to our instructions. In addition to services providers, other categories of third parties may include:
- Vendors/public institutions. To the extent that this is necessary in order to make use of certain services requiring special expertise (such as legal, accounting or auditing services) we may share your personal data with vendors of such services or public institutions that offer them (e.g. courts). The legal basis of this data processing is Art. 6(1)(f) GDPR.
- Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity; depending on the concrete issue, the legal basis for such processing may be Art. 6(1)(b), (c) or (f) GDPR.
- Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract. The legal basis for such processing would be Art. 6(1)(f) GDPR as such processes are in the legitimate interest of SessionForward.
Other than the cases mentioned above, we will only pass your data on to third parties without your express consent if we are obliged to do so by statutory law or an instruction by a public authority or court as outlined in our Terms of Service.
Notice regarding Third-Party Websites
The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by SessionForward. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
We want to Communicate with You
We may occasionally send you notification emails about updates to our product, legal documents, offer customer support or marketing emails. Except for cases where we are required to do so by law (e.g. notifying you of a data breach), you shall have the opportunity to unsubscribe from receiving these messages free of charge.
Your Data, Your Rights
You have a right to be informed of Personal Data processed by SessionForward, a right to rectification/correction, erasure and restriction of processing. You also have the right to receive from SessionForward a structured, common and machine-readable format of Personal Data you provided to us.
We can only identify you via your email address and we can only adhere to your request and provide information if we have Personal Data about you through you having made contact with us directly and/or you using our site and/or service. We cannot provide, rectify or delete any data that we store on behalf of our users or customers.
Where you have provided consent, you may withdraw it at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing it. Whenever you withdraw consent, you acknowledge and accept that this may have a negative influence on the quality of the SessionForward Site and/or Services. You further agree that SessionForward shall not be held liable with respect to any loss and/or damage to your Personal Data if you choose to withdraw consent.
Where Personal Data is processed for the above purposes on the basis of SessionForward’s legitimate interests, under the GDPR, you may object to such processing at any time. To do so please contact : [email protected].
In addition, you have the right to lodge a complaint with the data protection authority in your jurisdiction.
Duration of Processing
We will store your usage data until such time when you withdraw your consent for us to do so. All other data as specified above will be retained for as long as is necessary for the purpose(s) for which we originally collected it. We may also retain information as required by law.
International Transfers of Personal Data
SessionForward’s customer information is stored in the European Union. In some limited cases, customer information may be accessed from, or other data (e.g., e-mail) may be transferred to, the United States or other countries which may have data protection laws that are different from the laws where you live. SessionForward has taken appropriate safeguards to require that your Personal Data will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Data from children. If you learn that your child has provided us with Personal Data without your consent, you may contact us as set forth below. If we learn that we have collected any Personal Data in violation of Applicable Law, we will promptly take steps to delete such information and terminate the child’s account.
If you are a visitor of a SessionForward Enabled Site, this section applies to you.
SessionForward assists its users/customers in providing their end users with a better experience and service as well as assist them in diagnosing technical problems and analyzing user trends. Most importantly, through SessionForward’s services, the functionality of the SessionForward Enabled Site can be improved, making them more user-friendly, more valuable, and simpler to use for the end users.
You may opt-out from having SessionForward collect your information when visiting a SessionForward Enabled Site at any time by visiting our Opt-out page and clicking ‘Disable SessionForward’ or enabling Do Not Track (DNT) in your browser.
Networking Technology Products LLC,
8 Egnate Ninoshvili Street, Tbilisi, Georgia
Tel: +995 555 951 194
Email: [email protected]