GENERAL INFORMATION ON DATA PROTECTION AND PRIVACY
The individuals from which we may gather and use data in the context of this website are:
Website visitors; and
any other individuals that the organisation has a relationship with or may need to contact as a result of them interacting with this website.
1. DATA CONTROLLER & INQUIRIES
The data controller is:
Sisvel International S.A., 6, Avenue Marie Thérèse 2132, Luxembourg. Tax code and VAT number: LU23037240.
Referred to as “Sisvel”, “Us” or “We”.
Contact mail for privacy related issues: firstname.lastname@example.org.
Any inquiries about your data should be sent to the above email. It can also be sent directly to the company, if you prefer, in a letter to the listed address. We cannot guarantee prompt responses if physical mail is your chosen method of communication.
You have the right to make a complaint at any time to the Luxembourg Data Protection Authority (CNPD) if you have any issues (https://cnpd.public.lu/en.html). We would, however, appreciate the chance to deal with your concerns before you approach the CNPD, so please contact us in the first instance if possible.
1.1 Sisvel’s processing as Controller and related responsibilities
While managing our responsibilities as a Data Controller, we have third party providers who will deal with your data on our behalf (known as “Processors”). The responsibilities described below may be assigned to a processor, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
Ensure that all processing of Personal Data is governed by one of the lawful bases laid out in the GDPR;
Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of a Controller;
Cooperate, on request, with the supervisory authority in the performance of its tasks;
Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
2. DATA PROTECTION FRAMEWORK
Sisvel is based within the European Union (“EU”), and as such is a Data Controller according to the definition laid out by EU Regulation 2016/679 (“GDPR”, “Data Protection Legislation” or “EU GDPR”).
The Data Protection Legislation regulates the use of personal information generally. This means everyone must comply with seven data protection principles which say that personal data and its processing needs to be:
Fair, lawful and transparent;
For specified, explicit and legitimate purposes (purpose limitation);
Adequate, relevant and limited to what is necessary (data minimisation);
Accurate and, where necessary, kept up to date (accuracy);
Not kept longer than necessary (storage limitation);
Processed using appropriate security (integrity and confidentiality); and
3. PROCESSING YOUR DATA VIA OUR WEBSITE - LAWFUL BASIS
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we could collect and when we collect it from you:
Contact Data: This covers any data relating to your phone number, addresses & email addresses which we may receive as a result of sending us an email via the ‘Contact Us’ link on our website. Sisvel has a legitimate interest in processing the contact information provided by you in order to respond to you under Article 6.1.f of the GDPR. If the purpose or nature of the contact changes, other lawful bases may be relied upon. If this occurs, you will be informed. You may always request that we delete your data via email at mailto:email@example.com. Lawful basis: Legitimate interest.
Client area: We will gather basic information from you upon entering our client area which provides you business-related documents and information. Lawful basis: Contract.
Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us for our marketing newsletters. It will include your name & email address. Lawful basis: Consent.
Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us. This is used for the purpose of analytics, with your consent, as well as to improve site functionality. Lawful basis: Legitimate interest for technically necessary cookies. Consent for data collected via cookies that are not technically necessary.
Client business data: This is likely to be contact information, business email address and phone number. Lawful basis: Necessity for Contract or legitimate interest, depending on individual situation.
For further information on the lawful bases and what they mean, please refer to section 3.2 below.
During the course of our normal business activities Sisvel will not collect any special categories of Personal Data according to the GDPR.
Sisvel will access and use your personal data only for the purposes for which you have submitted it to us to (a) provide information to you, (b) make contact with you, (c) provide services to you, or (d) maintain the operations and security of the website and services we provide to you. We will not use your personal information for any other purposes, for example for the communication of marketing materials, unless we have your specific consent that permits us to do so.
3.2 Lawful Bases Explained
There are several justifiable reasons under the EU GDPR that allow the collection and processing of Personal Data. The primary bases we rely upon during the operation of our website and associated service are the following:
“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
“Compliance with legal obligations”: Organisations occasionally have to process data in order to comply with legal regulations and legal & regulatory requirements.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards. When legitimate interest is relied upon, Sisvel will conduct a Legitimate Interest Assessment (LIA) to validate the processing is not considered unfair or infringing on the data protection rights of any individuals we work with.
4. HOW WE USE YOUR DATA AND RECIPIENTS
4.1 Sources of Data
We primarily obtain the data from you (including via the devices you use) while visiting the site. If we do not collect the personal data directly from you, we will also tell you the source of the personal data and, if applicable, whether it is sourced from publicly available sources.
4.2 Recipients of Personal Data
When processing your data, we work with service providers who have access to your data. The categories of recipients are as follows:
software companies that enable us to provide our services, help us to improve them and/or serve us for marketing purposes (for example, to send newsletters, emails, manage customer contacts or applications);
public bodies and administrations to the extent that we are legally obliged to do so;
payment service providers;
social media platforms; and
service companies, such as tax advisors or lawyers.
Mailchimp [Existing clients only via legitimate interest]
Ariadne Digital Srl
Youtube, Inc. [Embedded video stats]
Linkedin, Inc. [?]
Yes [Certified under the Data Privacy Framework]
Email Provider [For contact mail]
Yes [Certified under the Data Privacy Framework]
For the purposes of fulfilling the contract, we may also disclose your personal data to anyone to whom we assign rights arising from the contractual relationship with you. In these instances, you will be directly informed.
4.3 Data transfers
We transfer Personal Data to third parties in order to provide website functionality & our service. We may also share your Personal Data with subcontractors when necessary and with your consent. The sub-contractors are also subject to our confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions.
There is a transfer of data to third countries outside of the European Union. Information we collect from you could be processed in the United States or other third countries. Some third countries have not currently received an adequacy decision from the European Union under Article 45 of the GDPR which means that your data may not receive the same level of protection there as it does under the UK GDPR and European GDPR.
4.3.1 Is my data shared with anyone else?
Sisvel is a part of the Sisvel group of companies. The Sisvel group operates, at times, as a group of controlled undertakings which, in accordance with the GDPR Art. 4 (19), Recital 37 + 48, allows for a legitimate interest in sharing certain personal data within the group. This data sharing is limited to what is necessary, and primarily applies to limited applicant data. Your data will not be shared with other companies within the group with no purpose. If your data is to be shared, you will be provided with notice and information related to the sharing.
4.3.2 Third-party links
4.4 Protection of your personal data
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. When we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession.
However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Sisvel to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us at firstname.lastname@example.org.
4.5 Change of purpose
We will only use your Personal Data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. YOUR RIGHTS
As a data subject under the EU GDPR, you have several rights:
Your right of access You have the right to ask us for copies of your personal information. This right always applies.
Your right to rectification You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.
Your right to erasure You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing If we are processing your personal data for our legitimate interests as stated above, you have the right to object to our further processing of your personal data. There are legitimate reasons why we may refuse your objection, which depend on why we are processing it. Where you have given consent, you are free to withdraw that consent at any time. Any request you make will not affect the lawfulness of the processing that took place prior to that request.
Your right to data portability This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering a contract and the processing is automated.
To exercise these rights, you can send an email to us at any point at the following email address: email@example.com.
We will handle any request to exercise these rights in accordance with the relevant laws, but please note that these rights may not be absolute. Sisvel may refuse or deny a request in accordance with these rules, though you will be informed why this is happening as well as our reasoning for such a decision.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may also need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
6. CHILDREN’S PERSONAL DATA
Sisvel and any services available from our website are not directed to people under the age of 16. If you learn that a child under the age of 16 has provided us with their personal information without having parental consent, please contact us at firstname.lastname@example.org in order for us to rectify the situation. We reserve the right to delete any such data where we suspect it relates to anyone under the age of 16.
7. WHEN DO WE DELETE YOUR DATA?
We will keep your personal data only for as long as is necessary to ensure we can fulfil our business requirements and to comply with our regulatory requirements and will then securely destroy or anonymise that data.
In addition, data may be stored beyond the outlined periods in certain rare circumstances where data must be kept in order to exercise legal rights or to comply with other legal obligations. In these cases, the data is deleted when a storage or retention period prescribed by law expires.
We store applicant documents for a period of six months if the application does not lead to an employment relationship and no further storage has been agreed.
If you would like to know how long we will keep a specific piece of data about you, please contact us.
9. CONTACTING SISVEL GROUP
通过本信息（“政策”），我们旨在说明 Sisvel International S.A.将基于准确、合法、公平、必要、透明以 及保护您的隐私和权利的原则开展数据收集和处理活动。
本网站由 Sisvel International SA 控制和管理；该公司的总部位于 6, Avenue Marie Thérèse 2132 Luxembourg Grand Duchy of Luxembourg – 税号和增值税号为 LU23037240（“Sisvel”或“我们”）。通过位于意大利的供应商 Kelyan SpA 所提供的支持，Sisvel 作为数据控制者，将保证其拥有的数据在处理的任何阶段的安全性、机密性和保护水平。
Cookie 是小型文本文件，网站可用之以提高用户体验。对于那些对本网站的正常运行来说绝对必要的cookie，我们可将其存储于您的设备上。对于所有其他类型的 cookie，我们则需要您的允许。本网站使用不同类型的 cookie。某些 cookie 由出现在我们页面上的第三方服务放置。Sisvel 通过使用 cookie 为浏览 www.sisvel.com 网站页面的用户提供简单高效的服务。通过禁用 cookie，我们的某些服务可能无法正常运行、某些页面将无法正确显示。我们的网站使用多种类型的 cookie，其中一些提升网站的使用效率，另一些则为用户带来特定功能。具体而言，我们的 cookie 允许：
Sisvel 使用的 Cookie 类型
此类 cookie 对于网站某些部分的正常运行是绝对必要的。可分为永久cookie (persistent cookies)和临时 cookies (session cookies)：
永久 cookie：不会随浏览器 的关闭而被清理，将保留至预设有效期
这些 cookie 从我们的网域发送，它们对于正确访问网站和提供技术服务而言是必要的。因此除非用户更改浏览器中的设置（此举将造成网站页面无法正确显示），否则这些cookie将被持续使用和发送。
此类 cookie 被用于收集有关网站使用情况的信息。Sisvel 将使用这些匿名统计分析信息，以改善网站的使用体验，并使内容更有趣和更具相关性，从而满足用户需求。此类 cookie 收集有关用户活动和他们访问网站的匿名数据。分析 cookie 由本网站或第三方网域发送。
这些 cookie 用于匿名收集网站用户如何使用网站的信息，例如：访问的页面、花费的时间、流量来源、地理位置信息。这些 cookie由第三方外部网域发送至本网站。
此类cookie在网站页面内整合了第三方开发的功能，例如社交网络中表达的图标和偏好，以便共享网站内容或使用第三方软件服务（例如，生成地图的软件和提供附加服务的附加软件）。这些 cookie 由第三方网域和在不同网站页面之间提供功能的合作伙伴网站发送。我们目前不使用此类 cookie，但将来可能会发生变化。
请注意，我们无权通过访问或控制第三方使用的 cookie 或其他技术来收集有关您兴趣和偏好的信息，并且这些第三方的信息处理情况并不受本政策的约束。请特别关注他们的信息政策（包括但不限于他们的个人信息保护政策或隐私政策）。
根据现行法律，因为技术 cookie对于提供所请求的服务至关重要，所以Sisvel 无须就使用技术 cookie 向用户征求同意。
对于所 有其他类型的 cookie，用户可以通过以下一种或多种方式授予同意：
通过调整用于网站页面导航的相关计算机程序的浏览器配置。您可以在相应的公司网站上找到一些最常见浏览器（例如 Windows Explorer、Edge、Safari、Chrome、Firefox、Opera）的设置。
公司的合法利益：处理您的联系方式和相关信息以与您适当地沟通并回应您的请求。 合同订立前置义务：以便在签订合同前应数据主体 的要求采取适当措施
与客户、供应商和业务合作伙伴进行交易和处理 Sisvel 服务的订单
向我们的客户提供约定的服务，例如但不限于就以下事宜联系您：与您达成业务合作和伙伴关系，帮助您从您的 IP 组合中创造价值；就潜在侵犯我们或我们客户权利的行为发送告知函；创建、运营专利池和其他形式的专利聚合；研发合作和/或标准化活动以及专利买卖活动
我们客户的合法利益：处理您的联系方式和相关信息以向我们的客户提供服务。 合同义务：在订立或履行合同所必需的范围内。 依照适用法律规定在合理的范围内处理个人自行公开或者其他已经合法公开的个人数据
通过 “职业”部分管理 Sisvel的职位空缺
合同订立前置义务：以便在签订合同前应数据主体的要求采取适当措施。 公司的合法利益：验证和认可候选人申请中所述的技能和经验。 同意：如候选人同意，则保留候选人申请以备将来空缺。 为订立、履行个人作为一方当事人的合同所必需，或者按照依法制定的劳动规章制度和依法签订的集体合同实施人力资源管理所必需
在招聘过程中保存；但如果征得候选人同意，可额外延长 2 年
我们不会将您的数据转让、出售、出租或以任何其他方式提供给第三方，除非向为 Sisvel 提供某些服务的供应商提供，但在任何情况下这些供应商都不得为自身目的处理这些数据。
同样，Sisvel 是一家全球性公司，因此您的个人数据可能会在 Sisvel 位于全球各地的关联公司之间共享。您可以通过访问 www.sisvel.com/contacts 查阅 Sisvel 关联公司的清单。本政策中规定的条款适用于 Sisvel 的所有关联公司，这些关联公司无权偏离本政策行事。
以上某些服务供应商和 Sisvel 关联公司可能位于欧盟以外的地区。在这种情况下，公司将确保此类数据传输建立在欧盟委员会的充分性决定的基础上或始终受到适当保护措施的保护，其中可能包括公共当局或机构之间存在具有法律约束力和可执行性的文书、签订经欧盟委员会批准的标准数据保护条款，符合经批准的行为守则制度、经批准的认证制度（同时接收方应当做出有约束力且可执行的承诺，表示愿意遵守这些保护措施以及保护数据主体权利）和具备有约束力的公司规则等GDPR 所确立的规则和制度。
数据主体可随时行使欧盟法规 2016/679 第 12、15 至 22 条或任何适用法律所述的权利，包括但不限于：