EU GDPR Fair Processing Notice
This EU GDPR Fair Processing Notice was last revised on June 25th, 2019.
Sontiq, Inc., ‘the Company’, is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the EU General Data Protection Regulation (GDPR). It applies to all members, not just those residents in the European Union.
Sontiq, Inc. is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under GDPR to notify you of the information contained in this privacy notice.
This notice does not form part of any contract to provide services. We may update this notice at any time.
We have appointed a Privacy Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Privacy Officer at the following email address: firstname.lastname@example.org or by mail to Sontiq Inc., 9920 Franklin Square Drive, Suite 250, Nottingham, MD, 21236, USA. Attn: Privacy Officer.
Data Protection Principles
When we process your personal data, we will always apply the core principles of the GDPR to ensure it is:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate as updated by you from time to time.
- Kept only as long as necessary.
- Kept securely.
In this section we outline the purposes for which we may process your data. For each ‘purpose’ we also list the types of data we may process and our legal basis for the processing it.
|Monitor / Inform / Alert|
Sontiq monitors your personal information and sends alerts as described on our web site. This includes:
|Types of personal data processed|| |
|Lawful basis for processing personal data|| |
|Types of personal data processed|| |
|Lawful basis for processing personal data|
|Marketing and Corporate|| |
|Types of personal data processed|| |
|Lawful basis for processing personal data|
Do we need your consent?
Under the GDPR consent is not considered a lawful basis for processing in situations where there is an imbalance in power – such as employment. Therefore, instead of seeking your consent we are required to apply one of the other legal bases – those outlined in Article 6 of the GDPR– namely:
- To perform our contract with you,
- To enable us to comply with legal obligations, and
- Using your personal information to pursue legitimate interests of our own provided your interests and fundamental rights do not override those interests.
For each of our processing activities listed in the tables above we have also detailed the legal basis that allows us to process your data.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to provide part of our service to you (such as monitoring your credit card for unlawful activity), or we may be prevented from complying with our legal obligations.
Change of Purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Will your personal data be subjected to automated decision making?
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you 21 days to request a reconsideration.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. We will transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. ‘Third parties’ includes third-party service providers (including contractors and designated agents) and other entities within our group.
The following activities may be carried out by third-party service providers:
- Name, address, date of birth, telephone number, email address monitoring
- Social security number monitoring
- Credit and credit score monitoring
- Driver’s license number monitoring
- Passport number monitoring
- Medical account number monitoring
- Credit card monitoring
- Bank account monitoring
- Monitoring bank and credit card transactions
- Social media account monitoring
- Court records
- Payday loan monitoring
- IT services
We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganization or group restructuring exercise, for system maintenance support and hosting of data.
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes, in accordance with our instructions and under the terms of a data processing agreement.
Transferring Information Outside of the EU
We will transfer the personal information we collect about you to countries outside the European Economic Area in order to perform our contract with you.
There is not an adequacy decision by the European Commission in respect of these countries, which means they are not deemed to provide an adequate level of protection for your personal information.
However, to ensure that your personal information does receive an adequate level of protection we have enrolled in the EU-US Privacy Shield to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the laws on data protection. To view our EU-US Privacy Shield Policy, please visit https://www.sontiq.com/eu-us-privacy-shield-privacy-policy/.
You can contact us if you require further information about these protective measures.
The Period for which Data is Stored
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a member we will retain and securely destroy your personal information in accordance with our data retention policy and/or applicable laws and regulations.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. You may do this by logging in to your account and reviewing the information from the Sontiq member dashboard. Please note that, for security, we cannot provide your full Social Security Number or your full credit card numbers.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. You may do this by logging in to your account and updating the information in the Sontiq member dashboard.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). Please note that we cannot provide monitoring or alerting services on personal information that you have chosen not to supply or to delete.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. You may do this by logging in to your account and temporarily removing such personal information from the Sontiq member dashboard.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please send an email to the Privacy Officer at email@example.com.
As stated above the processing of your personal data is based on legal basis other than your consent, however in the very limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please log in to your account and delete the information from the Sontiq member dashboard. If you require assistance with this, please contact our Member Services team, under the IdentityForce brand, by sending an email to firstname.lastname@example.org or by calling 877-694-3367. If you have any problems deleting your information, please send an email to the Privacy Officer at email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
No Fee Usually Required
You will not have to pay a fee to access your personal information in Sontiq-owned member dashboard(s), under either the IdentityForce or EZShield brand, while your account is current (or to exercise any of the other rights).
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Raising a Complaint
If you are unhappy with the way in which your personal data has been processed, you may in the first instance contact the Company’s Privacy Officer using the contact details above.
If you remain dissatisfied, then you have the right to apply directly to the UK Data Protection Authority for a decision – contact details below:
Information Commissioner’s Office
+440303 123 1113
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.