SEON Privacy Policy

Last updated: Friday, 4 May 2018

SEON (“we” or “us”) provides a unified risk management solution that helps businesses across various industries (our “Customers”) to detect, combat and prevent fraudulent online transactions and other types of cybercrime (our “Services”). Our vision is to create a safer environment for online businesses.

At SEON, we recognise that privacy is important. This Privacy Policy (the “Policy”) applies to the collection of data by us, our subsidiaries and our affiliates (collectively, “SEON”) and sets out our privacy practices and controls around the collection, use and disclosure of personal information, both through our website https://seon.io/ and its subdomains (collectively, the “Website”) and through the provision of our Services. This Policy also sets out your rights and the options available to you in respect of your information.

1. Personal Information we collect through our Website

1.1

We collect information, including Personal Information, in various ways. “Personal Information” is defined as any information relating to an identified or identifiable individual, such as name, address, telephone number or email address and other demographic information, as well as interests and preferences. We indicate to you the reason why you must provide us with your Personal Information, and whether you are in fact required to do so, at the time of the collection of your Personal Information. You will not be able to use or benefit from our Services if you do not provide us with the Personal Information necessary for us to carry out our Services.

Information provided by you

1.2

You can visit our Website without informing us of who you are or revealing any personal information about yourself. You may choose to provide us with Personal Information by making enquiries through our ‘Contact us’ page, by signing up for a SEON account, by updating your account information, when requesting white papers, reports, brochures or demos, when leaving a comment on our blog or otherwise posting or transmitting any information or content, when you attend our events or webinars, when you request help or support regarding our Services and/or when you sign up to our mailing list.

Information collected automatically

1.3

When you use our Website and Services, some information is collected via automated means. This includes, but is not limited to IP address, browser type and operating system, information about your visit, including the content and pages that you access and URL clickstream to, through and from our Website, the time you spend on our Website, as well as download errors and other page interactions. We may also rely on your IP address to ascertain your approximate location.

1.4

This information is collected automatically via standard server logs, cookies and clear GIFs (“Web Beacons”). For more information about our use of cookies and cookie preferences, please refer to the section titled “How we use cookies and similar technologies” below. We use this information to administer, operate, improve and tailor our Website.

1.5

We may collect:

1.5.1

Transaction data. When you place an order with us, we collect various data such as your name, email, the items you purchased, the price paid, shipping information and billing and payment method, however we will never collect or keep your complete credit card number;

1.5.2

Device data. We collect information about the device you use to access our Website, whether it is a personal computer or other mobile device, such as the model and other unique device identifiers, IP address, operating system, browser type and mobile network information;

1.5.3

Geolocation data. We collect town-approximate geolocation information when you use our Website;

1.5.4

Analytical data. We collect data regarding the frequency of your access to our Website and the pages and items that you view and interact with;

1.5.5

Cross references. We cross-reference, verify and enhance the accuracy of the aforementioned collected data by using publicly available third-party sources, including but not limited to online search engines, online ‘white pages’ and mapping services; and

1.5.6

Enquiries and communications. We collect information regarding all enquiries, including queries and complaints and for identification verification purposes. We also keep copies of all communications you send to us and collect any information that you include in the content of such communications.

2. How we use personal Information collected through our Website

2.1

We use the information collected through our Website for the following purposes:

2.1.1

To operate, maintain and optimise our Website;

2.1.2

To respond to enquiries and/or to provide you with access to resources and information you have requested from us and to respond to comments and questions and otherwise provide support to our users;

2.1.3

To tailor your user experience;

2.1.4

For network security and administration;

2.1.5

For trend monitoring and analysis of our Website, as well as for marketing and advertising purposes and in order to develop and provide promotional and advertising materials that may be useful, relevant or tailored to you, or otherwise of interest;

2.1.6

To maintain a record of our dealings with you;

2.1.7

To achieve various business purposes such as account verification, security, audits and compliance with applicable laws and regulations, including data protection law;

2.1.8

To investigate and prevent fraud, identity theft, spam and any other unauthorised access or unlawful activity;

2.1.9

To enforce our Terms of Service or to establish, exercise or defend our legal rights;

2.1.10

To achieve a specific purpose, in which case we will inform you of this purpose at the time of collection; and

2.1.11

For any other legitimate business and other purposes in respect of which we will notify you.

2.2

If you are located within the European Economic Area (“EEA”) or Switzerland, we will only process your Personal Information on the basis of valid legal grounds, including when:

2.2.1

You have already consented to our use of your Personal Information, for instance by accepting our use of cookies or similar technologies, or when you agree for us to send you various communications, such marketing and promotional material;

2.2.2

It is necessary for us to process your Personal Information so that we may provide you with products or respond to any enquiries;

2.2.3

We are required to process your Personal Information by applicable law or in order to comply with a legal or regulatory obligation; and/or when

2.2.4

We, or a third party, have a legitimate interest in using your Personal Information, such as securing and improving safety or to protect against and prevent fraud, or for data analysis purposes.

3. Personal Information we collect through our Services

3.1

We may collect Personal Information when our Customers subscribe to our Services in order to detect and prevent fraud and other malicious behaviour and to enable delivery of our Services.

Information collected automatically

3.2

When a Customer subscribes to our Services, they may place our cookies or run our JavaScript code in order to collect certain device identifiers and IP addresses. This process and the Personal Information collected as a result is no different to common web analytics tools and the information collected via that means. The information collected is then sent back to the Customer and we may also use it for further processing. For more information about our use of cookies and cookie preferences, please refer to the section titled “How we use cookies and similar technologies” below.

Information provided by you

3.3

Our Customers may also provide us with additional information for fraud analysis or system abuse purposes and this information may include elements of your Personal Data that you have consented to being shared with us.

Information we collect from our Customers (“Customer Information”)

3.4

We may collect Personal Information about our Customers when you register to use our Services, including but not limited to the company name, URL, company size and fraud-related information. We may also collect the Personal Information of individuals representing our Customers such as full name, email address, phone number and job title. If our Customers pay by credit card, we will not store full credit card data, although our payment processor will collect that information. We may also collect billing and billing contact information.

3.5

We may also use Personal Information provided to us by our Customers and individuals representing our Customers for marketing and promotional purposes. All recipients of marketing and promotional information are able to opt-out of receiving such information at any time. Please refer to the section titled “Unsubscribing from our mailing list” below.

4. How we use personal Information collected through our Services

4.1

We use Personal Information we collect:

4.1.1

To provide and bill for our Services;

4.1.2

To understand and analyse Customer use of our Services, including usage trends and preferences for internal business purposes;

4.1.3

To enhance, improve, operate and maintain our Services;

4.1.4

To develop new products, services, features and functionality;

4.1.5

To protect against and prevent fraudulent use of our Services and to investigate any unlawful or wrongful activity or unauthorised access to our Services;

4.1.6

To send Customer updates, technical alerts, security notifications and other communications such as providing customer service and support, contact for administrative purposes and to give notice of any changes to our Terms of Service;

4.1.7

To send Customers marketing information on the basis of their marketing preferences; and

4.1.8

For other legitimate business and other purposes, about which Customers will be notified.

5. Sharing of Personal Information and disclosure to third parties

5.1

We may share Personal Information collected through our Website and Services as follows:

5.1.1

Vendors, consultants and other service providers. We may share Customer and user Personal Information with certain trusted third party providers including vendors, consultants and other service providers whom we have engaged to assist us with our provision of our Website and our Services, for instance to process payments. We will only share Personal Information to the extent that it is necessary to do so for the performance of those functions, in accordance with the purposes set out in this Policy and in line with applicable laws, including data protection laws.

5.1.2

Business transfers. In the event of a corporate sale, acquisition, merger, reorganisation, dissolution, financing or other similar event, we may share Personal Information in connection with or during negotiations of such event or transaction, as permitted by law.

5.1.3

Data accuracy. We may share limited elements of your Personal Data that we have collected with trusted third parties and operators of online publicly available data sources, such as online search engines, in order to verify, cross-reference and enhance the accuracy of the data we collect.

5.1.4

Legal compliance. We may disclose Personal Information to a third party when (i) we are legally required to do so in order to comply with applicable laws, regulations, legal processes or governmental requests and (ii) to the extent that we believe it is necessary or appropriate to respond to claims, judicial orders, subpoenas, warrants or other process issued by a court of competent jurisdiction.

5.1.5

Vital interests and legal rights. We may share Personal Information with third parties if we believe it necessary in order to (i) protect the vital interests and property rights of any person, (ii) exercise, establish or defend our legal rights and (iii) prevent or cease any activity we consider to be illegal, unethical or legally actionable.

5.1.6

Corporate affiliates and transactions. We may provide Personal Information to our affiliates, who will only utilise such information according to the terms of this Policy. Affiliates are defined as any subsidiary, parent company or company under our control.

6. International Transfers

6.1

Your personal information may be transferred outside of the EEA, potentially to countries whose data protection laws and legal environments may not be adequate by EU protection standards. Please note that the third parties referred to within Section 5 may well operate outside of the EEA.

Your right to opt-out

6.2

It is your right to opt-out of having your Personal Data transferred to third party sources outside of the EEA. To exercise this right, please email legal@seon.io. Please note however that opting out may prevent us from providing you with certain fraud prevention and other Services.

7. How we use cookies and similar technologies

7.1

Cookies are small text files that are saved on your device when you visit (i) our Website and/or (ii) the websites of our Customers who are using our Services. Cookies are widely used in order to enable websites to function more effectively and also to provide various device, analytical or other information.

How we use cookies through our Website

7.2

We may use cookies to (i) personalise web pages when you visit our Website, (ii) remember you when you return and for easy navigation, (iii) provide you with offers, products and services, (iv) monitor web traffic routing and aggregate usage and (v) customise and improve our Website.

7.3

We work with various third parties, who monitor and analyse our site traffic and usage, such as web analytics service providers. Our Website may contain cookies and other tracking technology provided by these third parties, such as web beacons and embedded scripts, which are used for statistical purposes.

How we use cookies through our Services

7.4

Our Customers may place our cookies and other tracking technology on your device in order to collect information for the prevention of fraud and other malicious activity. As well as providing you with information about our cookies through this Policy, we also rely on our Customers to ensure that they obtain sufficient notice and appropriate consent from you for their use of such cookies on their sites and apps.

How to disable cookies

7.5

If you do not want us to deploy cookies on your browser, you can set your browser to reject cookies and most browsers allow you to automatically decline cookies. You may also have the option of declining or accepting the transfer of individual cookies. For further information, you may to refer to: http://www.allaboutcookies.org/manage-cookies

7.6

If you do not accept cookies, you may experience limited functionality when using our Website and you may not be able to access all portions of our Website.

7.7

If you disable the cookies placed by our Customers in order to prevent fraud and other malicious activity, you may not be able to access all of the services provided by our Customers on their websites.

7.8

We do not process or respond to “do not track” signals or other similar transmissions used to indicate a request to disable online tracking of users of our Website and Services.

8. Security

8.1

We will use appropriate and reasonable security measures to protect your Personal Information from unauthorised access, misuse, disclosure, loss, alteration or destruction. These security measures may be technical, administrative, organisational or physical. Although we will do our best to protect your Personal Information, please be aware than no website is completely secure, so aim to access our Website in a secure environment only.

9. Individual privacy rights

Access and deletion

9.1

We provide all our users and Customers with the opportunity to access, amend and delete their Personal Information, as required by applicable law. As part of the user account functionality on our Services, you may access your account settings by logging into your account and you may update various categories of Personal Information that you have provided to us.

9.2

If you wish to access, review, or modify or delete any other Personal Information that you have provided to us or that was automatically collected, please email legal@seon.io.

9.3

You may also request that we delete your user account on any of our Services at any time and we will comply with your request within a reasonable period of time however we may retain some of your Personal Information in order to comply with various legal or regulatory obligations or if we have a reasonable belief that there is a legitimate reason for us to keep your information.

European users

9.4

If you are located in the EEA, under the General Data Protection Regulation (“GDPR”), and Switzerland, you may have the right to the following:

9.4.1

To (i) request access to and receive information in respect of the Personal Information we hold about you, (ii) request that inaccurate Personal Information be updated and corrected, (iii) restrict or object to the processing of your Personal Information, (iv) request that Personal Information is anonymised or deleted, as appropriate, (v) exercise your right to data portability, whereby your Personal Information is easily transferred to another company and (vi) lodge a complaint with a relevant supervisory authority; and

9.4.2

Where your Personal Information has been provided to us with your consent, and the GDPR is applicable, you are able to withdraw your consent in relation to our processing of your Personal Information at any time, free of charge. Any such request will not affect the lawfulness of our processing before the withdrawal of your consent.

9.5

In some circumstances, the rights set out at Sections 9.4.1 and 9.4.2 may be limited by requirements of local law.

9.6

Please email legal@seon.io if you wish to exercise any such rights, or if you have any questions, comments or concerns regarding the manner in which we process your Personal Information. We will consider and respond to your request promptly and in accordance with all applicable laws and regulations.

Unsubscribing from our mailing list

9.7

You may ask us to remove your details from any of our mailing lists at any time by clicking “Unsubscribe” in any of our email communications. If you have any questions or issues regarding the “Unsubscribe” process, please email legal@seon.io. You may also use this email address to opt-out from receiving promotional emails from us and you may also write to us at the address provided at the end of this Policy.

9.8

Additionally, as part of the account functionality on our Services, we may allow you to view and modify settings regarding the nature and frequency of promotional communications that you receive from us.

9.9

It may take up to ten business days for us to process your opt-out request and we apologise for any promotional material you receive from us during this period.

9.10

You will continue to receive administrative messages from us regarding our Services after opting-out of receiving our marketing and promotional material.

Complaints

9.11

If you wish to make a general complaint about our privacy practices, you may email legal@seon.io. We will respond within a reasonable time and in accordance with all applicable laws and regulations.

10. Links to other websites

10.1

For your convenience, our Website and Services may contain links to other websites, products and services not operated by us. This Policy does not apply to and we are not responsible for the privacy, information or security practices provided on the websites, products or services of any such third parties. In order to protect your Personal Information we encourage you to carefully review the privacy and security policies of other websites, products and services that you access through our Website before providing any Personal Information to such third parties.

11. Changes to this Policy

11.1

We may occasionally update this Policy. When we do so, we will also revise the “Last updated” date at the top of this Policy. If any of these changes are material, we will notify you more directly, for instance by posting a notification on our Website or by sending you an email, or a message to your account. We encourage you to periodically review this Policy to stay informed of the latest modifications.

11.2

Your continued use of our Website and Services after such changes will mean that you have accepted our revisions.

12. Contacting us

12.1

If you have any questions, comments or concerns about this Policy, or to exercise your rights in relation to your Personal Information, you may contact us at the following address:

SEON Technologies Kft.
Attn: SEON.io Privacy Issues
Rumbach Sebestyen 15/A 1em
1075 Budapest
HUNGARY
legal@seon.io