Privacy Policy

Privacy Facts

Our privacy facts.

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Who is the provider of this site? Ethyca Inc
More Info
What data do we collect about you through Ethyca.com
If you accepted our cookies Details here
If you opted in to receiving our newsletter Email Only
If you didn’t accept our cookies or join our newsletter Nothing!
How we use your data at ethyca.com List of Purposes
How we use data collected through our Data Privacy Solutions List of Purposes
Legal basis for using your data
If you accepted our cookies Consent
If you opted in to receiving our newsletter Consent
If you are a Customer’s Authorized User Consent
Privacy Rights Your Rights
How long we keep your data
If you accepted our cookies Details here
If you opted in to receiving our newsletter Until You Say Stop
If you are a Customer’s Authorized User Details here
Where we store your data
If you accepted our cookies On your computer
If you opted in to receiving our newsletter Our Server (USA)
If you are a Customer’s Authorized User Our Server (USA)
Who we share your data with
If you accepted our cookies Details Here
If you opted in to receiving our newsletter We don’t
If you are a Customer’s Authorized User Details Here
If you didn’t accept our cookies or join our newsletter We have nothing
We use some cookies Manage Preferences
But what are cookies we hear you ask? Google and Mozilla explain them well here.

Privacy Long Read

If you’re interested in more details, see the longer version below.

List of Purposes
  • If you did not consent to the cookie or opt in to our newsletter, we don’t collect any of your data and so cannot use your data for any purpose!
  • If you agree to the use of the cookies we use, we will only use the data collected for analytics related to our site or advertising for Ethyca. However, you should know that these cookies are provided by Facebook and Google amongst others and thus, you may be sharing data with them. For more information about each of their cookie policies and how to manage your rights, you can view Google, Facebook, Hubspot and Linkedin.
  • If, in relation to companies using our Data Privacy Solutions (“Customers”) you are an individual employed or engaged by a Customer and are authorized to access and use our Data Privacy Solutions (an “Authorized User”), we use your personal information only as necessary to provide the Data Privacy Solutions or otherwise fulfil our obligations to our Customers.  This includes administering our relationship and otherwise communicating with Customers and Authorized Users, providing technical support to Customers and Authorized Users, allowing our Data Privacy Solutions to function and display properly, building or improving the quality of our service and Data Privacy Solutions, detecting data security incidents and protecting against fraudulent or illegal activity, to comply with applicable laws and regulations and to exercise or defend legal claims.
  • If you want our newsletter, you will need to provide us an email address. We only use the email address to send you the newsletter. That’s it. Nothing else.
We use Hubspot, Linkedin, Facebook and Google for our analytics and advertising and want you to understand exactly what each cookie does so that you can control them as you wish. We’ve listed these in detail here but if you’d like more information or have questions, our privacy team will happily help you at privacyquestion@ethyca.com
You can also manage your preferences for cookies here.

Google We use Google analytics for monitoring performance, site traffic to make site improvements.
Cookie Name Description Expiration
Google _ga Used for Google Analytics to measure site performance and ensure a good user experience. 24 Months
Google _gid Used to anonymously identify between users visiting our site for performance measurement. 24 Hours
Google _gat Used to throttle, or manage, request rates to prevent overloading of services. 1 Minute
Google __gac Used to measure interactions from ad campaigns that we have run. 18 Months
Google 1P_JAR Used to measure interactions from ad campaigns that we have run. 1 Minute
DoubleClick We use DoubleClick for re-targeting, optimization, reporting and attribution of online adverts.
Cookie Name Description Expiration
DoubleClick IDE Used to assist in targeting ads across Google advertising properties and ad networks 2 Months
DoubleClick DSID Used to assist in targeting ads across Google advertising properties and ad networks. 14 Days
Hubspot We use Hubspot for our marketing activities, which involves newsletters and behavior based advertising.
Cookie Name Description Expiration
Hubspot __hs_opt_out This cookie is used by Hubspot’s opt-in privacy policy to remember not to ask you to accept cookies again if you have opted out. 13 Months
Hubspot __hs_do_not_track This cookie is used to prevent the tracking code from sending any information to HubSpot if you have requested not to be tracked. 13 Months
Hubspot hs_ab_test This cookie is used to consistently serve you the same version of an A/B test page if you’ve view the page before. 13 Months
Hubspot hs-messages-is-open This cookie is used to determine and save whether the chat widget is open for future visits. 13 Months
Hubspot hs-messages-is-open This cookie is used to determine and save whether the chat widget is open for future visits. 30 Minutes
Hubspot hs-messages-hide-welcome-message This cookie is used to prevent the chat widget welcome message from appearing again for one day after it is dismissed. 1 day
Hubspot __cfduid This cookie is set by HubSpot’s CDN (content delivery network) provider, Cloudflare. It helps Cloudflare detect malicious visitors to our website and minimizes blocking legitimate users. 30 days
Hubspot __cfruid This cookie is set by HubSpot’s CDN provider to support their rate limiting policies, ensuring no abuse of their services. End of visit (session)
Intercom We use Intercom to power our customer support messaging service and to answer your product questions.
Cookie Name Description Expiration
Intercom intercom-id-ethyca Anonymous visitor identifier cooker to anonymously identify unique visitors 9 Months
Intercom intercom-session-ethyca Keep track of sessions, meaning the unique visits to the site, to ensure you see the correct support conversations associated with your unique id 1 week
Linkedin We use Linkedin to for tracking conversion from Linkedin members for our advertising.
Cookie Name Description Expiration
Linkedin UserMatchHistory Used to identify you as a user for Linkedin advertising. 30 days
Linkedin li_sugr Identifies the type of browser you’re using for analytics when the IP address used does not match your known country. 3 Months
Linkedin li-oatml Indirectly identifies Linkedin members for conversion tracking, retargeting and analytics. 1 Month
.adsymptotic.com U Identifies the type of browser you’re using for analytics when the IP address used does not match your known country. 3 Months
Facebook We use Facebook for tracking performance from our advertising and creating ads relevant to visitors from our site.
Cookie Name Description Expiration
Facebook fbq fbevents.js Used to identify and analyze advertising to our users, to ensure that any Facebook advertising you receive on Ethyca website is relevant to you. 28 days
Newsletter Information
In the past 12 months, if you have chosen to opt in to receiving our newsletter, we have collected your email address.
Data Privacy Solutions Information
If you have used an Ethyca powered data privacy system to request your data rights anywhere in the world, we have collected the minimum information possible in order to ensure your rights were met. We’ve listed below what that information is, how it’s used and how long it’s stored for:

Collected How it’s Used How long it’s Stored
Unique Identifier In order to safely manage your data rights, we have to be sure you are you who you say you are. A unique identifier is typically your email address, phone number or device id, however other unique identifiers depending on the businesses needs could extend to government issued ID. We only use this to demonstrate your identity and manage your rights to access, erase, rectify or copy your information. Due to data privacy regulations we hold this as part of a secure audit trail to demonstrate compliance – so that you and the business you requested your information from can safely prove they did the right thing with your information.
Privacy Rights
You should always have the following rights:

  • Access the information we have about you.
  • Know where we collected information with your consent, and withdraw consent.
  • Erase the information we have about you.
  • Contact us about a concern you have related to your privacy on this website.
  • File a complaint with your data protection authority if you have a data protection concern related to this website.

To exercise any of the above rights, please contact us using the contact information listed below under “Contact Us About A Privacy Concern”. We will not discriminate against you for exercising any of these rights.

You can see the individual expiration for each cookie we use from our advertising partners in the Cookie Information Table above, however most expire in less than a month with a handful being stored for 24 months.
How long we keep your data if you opted in to receiving our newsletter
When you sign up to get our newsletter you agree that we can store, and use your email address to provide you with the newsletter. However, at any time you can unsubscribe from our newsletter and we will stop sending you the newsletter and we will remove your email address from our system. You can do that by following the link at the bottom of the newsletter.
How Long We Keep Your Data If You Use Our Data Privacy Solutions
We store your personal information, typically a unique identifier for you in our Data Privacy Solutions for the term of the relevant Customer’s subscription. This information is used for the sole purpose of demonstrating compliance with relevant data privacy regulations and stored for the duration of the customer’s subscription unless applicable law or regulations require or permit a longer retention period.
The cookies we use are provided to us by Google, Facebook, Hubspot and Linkedin. Details about these cookies are available here and you can manage your preferences here
Where We Store Your Data If You Opted In To Receiving Our Newsletter
We provide this service through our own mail sending service and store the emails we receive from people subscribed to our newsletter on our server located on the east coast of the United States.
Where We Store Your Data If You Use Our Data Privacy Solutions
We store personal information collected in relation to our Data Privacy Solutions on our server located on the east coast of the United States.
We don’t share your data with anyone. However, the cookies we use for analytics and advertising are provided to us by Google, Facebook and Linkedin. Details about each set of cookies are available here: Google, Facebook, Hubspot and Linkedin.
Who We Share Your Data With If You Opted In To Receiving Our Newsletter
We only use your email to send you our newsletter if you have opted into that service. We do not share your email address with anyone. That’s it. Period. You can unsubscribe any time here.
Who We Share Your Data With If You Use Our Data Privacy Solutions
We share personal information collected in relation to our Data Privacy Solutions with service providers for the purpose of providing our Data Privacy Solutions and fulfilling our obligations to our Customers. We may also share personal information with an individual’s consent or in the context of any sale, merger or acquisition. We do not otherwise share with anyone, and for the avoidance of doubt, do not “sell”, personal information collected through our Data Privacy Solutions, nor have we done so in the past 12 months.
Our Policies Concerning Children
Our site and Data Privacy Solutions are not directed to children under 13, nor do we knowingly collect any information from or about such children. If you believe that a child under 13 has provided information about them to us, please promptly contact us and we will endeavor to investigate and delete such information from our systems.
Standard Contractual Clauses
For the purposes of Article 26(2) of Directive 95/46/EC for the transfer of personal data to processors established in third countries which do not ensure an adequate level of data protection,
The Customer, as defined in the Ethyca Customer Master Service Agreement (the “data exporter”)
And
Ethyca Inc., 45 West 29th Street RM501, New York, NY 10001 (the “data importer”)
each a ‘party’; together ‘the parties’,
HAVE AGREED on the following Contractual Clauses (the Clauses) in order to adduce adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of individuals for the transfer by the data exporter to the data importer of the personal data specified in Appendix 1.Clause 1
Definitions
For the purposes of the Clauses:
personal data’, ‘special categories of data’, ‘process/processing’, ‘controller’, ‘processor’, ‘data subject’ and ‘supervisory authority’ shall have the same meaning as in Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data;
‘the data exporter’ means the controller who transfers the personal data;
the data importer’ means the processor who agrees to receive from the data exporter personal data intended for processing on his behalf after the transfer in accordance with his instructions and the terms of the Clauses and who is not subject to a third country’s system ensuring adequate protection within the meaning of Article 25(1) of Directive 95/46/EC;
‘the subprocessor’ means any processor engaged by the data importer or by any other subprocessor of the data importer who agrees to receive from the data importer or from any other subprocessor of the data importer personal data exclusively intended for processing activities to be carried out on behalf of the data exporter after the transfer in accordance with his instructions, the terms of the Clauses and the terms of the written subcontract;
‘the applicable data protection law’ means the legislation protecting the fundamental rights and freedoms of individuals and, in particular, their right to privacy with respect to the processing of personal data applicable to a data controller in the Member State in which the data exporter is established;
‘technical and organisational security measures’ means those measures aimed at protecting personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.Clause 2
Details of the transfer
The details of the transfer and in particular the special categories of personal data where applicable are specified in Appendix 1 which forms an integral part of the Clauses.Clause 3
Third-party beneficiary clause
The data subject can enforce against the data exporter this Clause, Clause 4(b) to (i), Clause 5(a) to (e), and (g) to (j), Clause 6(1) and (2), Clause 7, Clause 8(2), and Clauses 9 to 12 as third-party beneficiary.
The data subject can enforce against the data importer this Clause, Clause 5(a) to (e) and (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where the data exporter has factually disappeared or has ceased to exist in law unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law, as a result of which it takes on the rights and obligations of the data exporter, in which case the data subject can enforce them against such entity.
The data subject can enforce against the subprocessor this Clause, Clause 5(a) to (e) and (g), Clause 6, Clause 7, Clause 8(2), and Clauses 9 to 12, in cases where both the data exporter and the data importer have factually disappeared or ceased to exist in law or have become insolvent, unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law as a result of which it takes on the rights and obligations of the data exporter, in which case the data subject can enforce them against such entity. Such third-party liability of the subprocessor shall be limited to its own processing operations under the Clauses.
The parties do not object to a data subject being represented by an association or other body if the data subject so expressly wishes and if permitted by national law.Clause 4
Obligations of the data exporter
The data exporter agrees and warrants:

      1. that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;
      2. that it has instructed and throughout the duration of the personal data-processing services will instruct the data importer to process the personal data transferred only on the data exporter’s behalf and in accordance with the applicable data protection law and the Clauses;
      3. that the data importer will provide sufficient guarantees in respect of the technical and organisational security measures specified in Appendix 2 to this contract;
      4. that after assessment of the requirements of the applicable data protection law, the security measures are appropriate to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing, and that these measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;
      5. that it will ensure compliance with the security measures;
      6. that, if the transfer involves special categories of data, the data subject has been informed or will be informed before, or as soon as possible after, the transfer that its data could be transmitted to a third country not providing adequate protection within the meaning of Directive 95/46/EC;
      7. to forward any notification received from the data importer or any subprocessor pursuant to Clause 5(b) and Clause 8(3) to the data protection supervisory authority if the data exporter decides to continue the transfer or to lift the suspension;
      8. to make available to the data subjects upon request a copy of the Clauses, with the exception of Appendix 2, and a summary description of the security measures, as well as a copy of any contract for subprocessing services which has to be made in accordance with the Clauses, unless the Clauses or the contract contain commercial information, in which case it may remove such commercial information;
        1. that, in the event of subprocessing, the processing activity is carried out in accordance with Clause 11 by a subprocessor providing at least the same level of protection for the personal data and the rights of data subject as the data importer under the Clauses; and
        2. that it will ensure compliance with Clause 4(a) to (i).

Clause 5
Obligations of the data importer

  1. The data importer agrees and warrants:to process the personal data only on behalf of the data exporter and in compliance with its instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees to inform promptly the data exporter of its inability to comply, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
  2. that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the instructions received from the data exporter and its obligations under the contract and that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by the Clauses, it will promptly notify the change to the data exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
  3. that it has implemented the technical and organisational security measures specified in Appendix 2 before processing the personal data transferred;
  4. that it will promptly notify the data exporter about:
    1. any legally binding request for disclosure of the personal data by a law enforcement authority unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation;
    2. any accidental or unauthorised access;
    3. and any request received directly from the data subjects without responding to that request, unless it has been otherwise authorised to do so;
  5. to deal promptly and properly with all inquiries from the data exporter relating to its processing of the personal data subject to the transfer and to abide by the advice of the supervisory authority with regard to the processing of the data transferred;
  6. at the request of the data exporter to submit its data-processing facilities for audit of the processing activities covered by the Clauses which shall be carried out by the data exporter or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable, in agreement with the supervisory authority;
  7. to make available to the data subject upon request a copy of the Clauses, or any existing contract for subprocessing, unless the Clauses or contract contain commercial information, in which case it may remove such commercial information, with the exception of Appendix 2 which shall be replaced by a summary description of the security measures in those cases where the data subject is unable to obtain a copy from the data exporter;
  8. that, in the event of subprocessing, it has previously informed the data exporter and obtained its prior written consent;
  9. that the processing services by the subprocessor will be carried out in accordance with Clause 11;
  10. to send promptly a copy of any subprocessor agreement it concludes under the Clauses to the data exporter.

Clause 6
Liability

  1. The parties agree that any data subject, who has suffered damage as a result of any breach of the obligations referred to in Clause 3 or in Clause 11 by any party or subprocessor is entitled to receive compensation from the data exporter for the damage suffered.
  2. If a data subject is not able to bring a claim for compensation in accordance with paragraph 1 against the data exporter, arising out of a breach by the data importer or his subprocessor of any of their obligations referred to in Clause 3 or in Clause 11, because the data exporter has factually disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the data subject may issue a claim against the data importer as if it were the data exporter, unless any successor entity has assumed the entire legal obligations of the data exporter by contract or by operation of law, in which case the data subject can enforce its rights against such entity. The data importer may not rely on a breach by a subprocessor of its obligations in order to avoid its own liabilities.
  3. If a data subject is not able to bring a claim against the data exporter or the data importer referred to in paragraphs 1 and 2, arising out of a breach by the subprocessor of any of their obligations referred to in Clause 3 or in Clause 11 because both the data exporter and the data importer have factually disappeared or ceased to exist in law or have become insolvent, the subprocessor agrees that the data subject may issue a claim against the data subprocessor with regard to its own processing operations under the Clauses as if it were the data exporter or the data importer, unless any successor entity has assumed the entire legal obligations of the data exporter or data importer by contract or by operation of law, in which case the data subject can enforce its rights against such entity. The liability of the subprocessor shall be limited to its own processing operations under the Clauses.

Clause 7
Mediation and jurisdiction

  1. The data importer agrees that if the data subject invokes against it third-party beneficiary rights and/or claims compensation for damages under the Clauses, the data importer will accept the decision of the data subject:
    1. to refer the dispute to mediation, by an independent person or, where applicable, by the supervisory authority;
    2. to refer the dispute to the courts in the Member State in which the data exporter is established.
  2. The parties agree that the choice made by the data subject will not prejudice its substantive or procedural rights to seek remedies in accordance with other provisions of national or international law.

Clause 8
Cooperation with supervisory authorities

  1. The data exporter agrees to deposit a copy of this contract with the supervisory authority if it so requests or if such deposit is required under the applicable data protection law.
  2. The parties agree that the supervisory authority has the right to conduct an audit of the data importer, and of any subprocessor, which has the same scope and is subject to the same conditions as would apply to an audit of the data exporter under the applicable data protection law.
  3. The data importer shall promptly inform the data exporter about the existence of legislation applicable to it or any subprocessor preventing the conduct of an audit of the data importer, or any subprocessor, pursuant to paragraph 2. In such a case the data exporter shall be entitled to take the measures foreseen in Clause 5(b).

Clause 9
Governing law
The Clauses shall be governed by the law of the Member State in which the data exporter is established.

Clause 10
Variation of the contract
The parties undertake not to vary or modify the Clauses. This does not preclude the parties from adding clauses on business related issues where required as long as they do not contradict the Clause.

Clause 11
Subprocessing

  1. The data importer shall not subcontract any of its processing operations performed on behalf of the data exporter under the Clauses without the prior written consent of the data exporter. Where the data importer subcontracts its obligations under the Clauses, with the consent of the data exporter, it shall do so only by way of a written agreement with the subprocessor which imposes the same obligations on the subprocessor as are imposed on the data importer under the Clauses. Where the subprocessor fails to fulfil its data protection obligations under such written agreement the data importer shall remain fully liable to the data exporter for the performance of the subprocessor’s obligations under such agreement.
  2. The prior written contract between the data importer and the subprocessor shall also provide for a third-party beneficiary clause as laid down in Clause 3 for cases where the data subject is not able to bring the claim for compensation referred to in paragraph 1 of Clause 6 against the data exporter or the data importer because they have factually disappeared or have ceased to exist in law or have become insolvent and no successor entity has assumed the entire legal obligations of the data exporter or data importer by contract or by operation of law. Such third-party liability of the subprocessor shall be limited to its own processing operations under the Clauses.
  3. The provisions relating to data protection aspects for subprocessing of the contract referred to in paragraph 1 shall be governed by the law of the Member State in which the data exporter is established.
  4. The data exporter shall keep a list of subprocessing agreements concluded under the Clauses and notified by the data importer pursuant to Clause 5(j), which shall be updated at least once a year. The list shall be available to the data exporter’s data protection supervisory authority.

Clause 12
Obligation after the termination of personal data-processing services

  1. The parties agree that on the termination of the provision of data-processing services, the data importer and the subprocessor shall, at the choice of the data exporter, return all the personal data transferred and the copies thereof to the data exporter or shall destroy all the personal data and certify to the data exporter that it has done so, unless legislation imposed upon the data importer prevents it from returning or destroying all or part of the personal data transferred. In that case, the data importer warrants that it will guarantee the confidentiality of the personal data transferred and will not actively process the personal data transferred anymore.
  2. The data importer and the subprocessor warrant that upon request of the data exporter and/or of the supervisory authority, it will submit its data-processing facilities for an audit of the measures referred to in paragraph 1.
We welcome your questions on your privacy, it’s what we’re here for. You can reach us at: privacyquestion@ethyca.com
Contact us about a privacy concern