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Privacy Agreement, Terms of Service, Cookies Policy of the PALADIN RISK ASSESSMENT INTERNATIONAL, PRAI (a department of COBRA SYSTEMS LLC) and all affiliated web sites

Please review the following Agreement carefully before using the PRAI website.

BY USING THIS WEBSITE AND/OR VIEWING MATERIAL ON THIS WEBSITE, YOU AGREE TO BECOME BOUND BY THE TERMS OF THIS AGREEMENT. IF YOU DO NOT AGREE TO TERMS OF THIS AGREEMENT, DO NOT CONTINUE USE THIS WEB SITE OR ANY PORTION THEREOF IN ANY FORM OR MANNER.

PART ONE: Cookie Policy

PART TWO: Data Collection and Privacy rights

PART ONE: Cookie Policy

COOKIES POLICY
This policy covers our use of the information collected by PRAI websites during your visit.

Cookies, Policy
What is a “cookie”?
A "cookie" is a text file containing small amounts of information which a server downloads to your personal computer (PC) or mobile when you visit a website. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at:
www.allaboutcookies.org and www.youronlinechoices.com

There are different types of cookies we may use now in in the future which are used to do different things, such as letting you navigate between different pages on a website efficiently, remembering preferences you have given a website, and improving your overall experience. Others are used to provide you with advertising which is more tailored to your interests, or to measure the number of site visits and the most popular pages users visit.

Session based cookies v. Persistent cookies
Some cookies are allocated to your PC only for the duration of your visit to a website, and these are called session based cookies. These automatically expire when you close down your browser. Another type of cookie would remain on your PC for a period of time. These are known as “persistent” cookies.
The cookies used on all our sites are based on the International Chamber of Commerce guide for cookie categories:
Strictly necessary
Performance
Functionality
Targeting
Types of cookies we use

Strictly necessary cookies
These cookies enable services you have specifically asked for. For those types of cookies that are strictly necessary, no consent is required. These cookies are essential in order to enable you to move around our Websites and use its features, such as accessing secure areas of the Website.

For example these cookies will:
remember information you’ve entered on forms when you navigate to different pages in a single session,
identify you as logged in to the Website
These cookies don't gather any information about you that could be used for marketing or remembering where you've been on the internet. These cookies are not used to gather information that could be used to advertise products or services to you or remember your preferences or username beyond your current visit.

Accepting these cookies is a condition of using the website, so if you disable these cookies we cannot guarantee or predict how our website will perform during your visit. However, if you do continue using our web sites you agree to this cookie policy.
Strictly necessary” cookies provided through our web sites - here is a list of the cookies we have defined as 'strictly necessary'.

"ASP.NET_SessionId" Standard cookie required by our website to make the site work
"website #lang" Standard cookie to make the site available in multiple languages as required
Performance cookies

'Performance' cookies collect information about how you use our website e.g. which pages you visit, and if you experience any errors. We use these only to improve our site or measure response rates. All information collected by these cookies is anonymous and does not in any way impact on your privacy. We need to use them to maintain our site's effectiveness and ease of use and to improve how our websites work, understand what interests our users or measure how effective certain features of our Website are.

For example we use these to provide statistics on how our Websites are used. We do not pass this information to anyone. We also use performance cookies to help us improve the website by measuring any errors that occur or test different designs of our website.

In some cases, some of these cookies are managed for us by third parties. Where cookies are managed by third parties, any data may be used by such third parties but all data is collected in anonymised form and is used in aggregate which does not allow us to extract personal information about the users.

Using our site indicates that you accept the use of 'Performance' cookies. Accepting these cookies is a condition of using the Website, so if you prevent them we cannot guarantee how our site will perform for you.

Performance cookies that may be provided on our sites:
Here is a list of cookies we classify as “performance cookies”
“__utma” Standard google analytics cookies, used to provide anonymous statistics about how our site is used
“__utmb”
“__utmc”
“__utmz”

Functionality cookies
'Functionality' cookies are used to provide services or to remember settings and choices you make to improve your experience during your visit.
For example, these cookies:
Show you when you are logged into the website
Will remember your log-in details
Will remember the settings you've applied such as preferences,
Will remember whether we've already asked you if you want to fill in a survey
Measure traffic received from various websites
Functionality cookies collect non-identifiable data. No personal details are stored in this process and the information collected is only used in aggregate. We sometimes share some of the information with partners to provide a service on our website. In addition, some of these cookies are managed for us by third parties. In any case, the information shared or collected by third parties is only to be used to provide the service, product or function and not for any other purpose.

Functionality cookies provided on our sites:

We will only collect functionality cookies based on your selection. If you accept the use of cookies we will store this information in a Functionality cookie named ‘cookiesettings’.

“cookiesettings” A cookie required to ensure we continue to collect cookies as per your agreement
Targeting cookies (not used on this website)

These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign.

We do not use targeting cookies on our sites.

How we collect your consent
When you enter our sites, you will see a notice requesting your consent to use cookies along the following lines (subject to change):
"Our website uses cookies to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to use the site, you are agreeing to our use of cookies."
Having seen this notice you are agreeing to our use of cookies by continuing to browse the site.

Browser settings
Cookies can also be removed from your PC using browser settings but there will still be some deterioration in the service you receive (for example you may not be able to access a page you earlier personalized).
Your browser lets you choose whether to accept, not to accept or to be warned before accepting cookies. These can be found in the advanced preferences.

If you delete all your cookies you will have to update your preferences with us again.
If you use a different device, computer profile or browser you will have to tell us your preferences again.

This policy applies to all PRAI Security web sites.
We cannot be responsible for the policies and practices of other web sites even if:
You accessed the third party web site using links from our web sites; or
You linked to our web sites from a third party web site
We recommend that you check the policy of each site you visit and contact the owner or operator of such web site if you have any concerns or questions.

For more information about our policy, please contact: dataprotection@paladin-risk.com

 

PART TWO: DATA COLLECTION AND PRIVACY RIGHTS

The PRAI Group 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 in accordance with the General Data Protection Regulation (GDPR).

It contains important information on how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

PRAI Security collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the GDPR which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

WHAT INFORMATION DO WE COLLECT
Personal data, or personal information, 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).
On our websites we collect and use personal information (which may include name, address, telephone number and email) in order to:
Respond to queries or requests submitted by you
Process orders or applications submitted by you
Supply to you service, course, training
Administer or otherwise carry out our obligations in relation to any agreement you have with us
Anticipate and resolve problems with any services supplied to you
INFORMATION COLLECTED FROM OTHER SOURCES

We collect information to analyse the performance of our websites and how different parts of our website are used. We may use Google Analytics to do this.
Google analytics stores information about how users get to our sites and from which device types, how content is being used whilst on the site and how long users spend on our site.
Google Analytics also provides information on interests and demographics of our visitors.
The information is collected using a tag placed on our websites and does not relate to any personally identifiable information being collected.

You can read Googles Data Processing Amendment online here https://www.google.com/analytics/terms/dpa/dataprocessingamendment_20160909.html

You can read Googles Data retention policy here https://policies.google.com/technologies/retention

We may set our analytics not to expire i.e. the information will be retained in order to allow us to analyse trends in our website usage over time.

HOW CAN I OPT-OUT OF THIS DATA COLLECTION
If you want to opt out of Google Analytics collection you can install a browser add on.
If you wish to opt out of data collection for demographic and interest data you can do this using Google Ad Settings here https://policies.google.com/technologies/ads

WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We will share personal information with other PRAI Security branches and businesses as appropriate in order to respond to your queries or requests.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party and we will only provide your personal information which we consider is necessary for the performance of that reason.

WHETHER WE NEED YOUR CONSENT
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

We will hold personal data for the period we are required to retain this information by applicable tax law (currently up to 10 years). In some circumstances we may anonymise 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.

PRAI Security has agreed to retain the information collected in Google Analytics indefinitely in order to allow us to analyse trends in our website usage over time. This is not personally identifiable information.

TRANSFER OF YOUR INFORMATION OUT OF THE EEA
We may transfer your personal information to other PRAI Security businesses which are located outside the European Economic Area (EEA) in order to respond to any queries submitted to us via our website or social channels.

You can see the full list of the countries where PRAI Security operates can be found on the home of our website.

Some of these countries do not have the same data protection laws as the USA, United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to suitable relevant safeguards eg European Commission approved contract (of the GDPR that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.

YOUR RIGHTS
Under the GDPR you have a number of important rights free of charge. Under certain circumstances, you have the right to:
Request access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address.
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.
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).
Object to processing of your personal information where we are processing your personal information for direct marketing purposes.
Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
Object in certain other situations to our continued processing of your personal information.
Request the transfer of your personal information to another party.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation which is accessible via https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/. These can serve to you as a guide.

In some circumstances you can claim compensation for damages caused by our breach of any data protection laws.
If you would like to exercise any of those rights, please:

email to us at dataprotection@paladin-risk.com
let us have enough information to identify you,
let us have proof of your identity and address (a copy of your driving license or passport for instance), and
let us know the information to which your request relates.
In the 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 contact dataprotection@paladin-risk.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. It may take us up to 30 days to process your request. We recommend to you to contact us after 2 weeks after your initial request if you haven't heard from us by then.

KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

DATA PROTECTION OFFICER
We have appointed a data protection officer (DPO) 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 DPO by emailing dataprotection@paladin-risk.com
You have the right to complain to the appropriate Data protection authorities, such as the appropriate EU Commission. However, if you have any issues, we invite you to contact us first in order to clarify.

CHANGES TO THIS PRIVACY NOTICE
This privacy notice was published on 10th May 2018 and last updated on 24nd May 2018.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice on this page http://www.paladin-risk.com/privacy_agreement.html

HOW TO CONTACT US
Please contact or Data Protection Officer on dataprotection@paladin-risk.com if you have any questions about this privacy notice or the information we hold about you.
If you would like to report any issues with our websites please also contact dataprotection@paladin-risk.com

 

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