Last updated: November 16, 2018
This Privacy Notice (this “Notice”) describes the policies and practices of GAP Intelligence, Inc., a California, U.S.A. Corporation (“GAP” or “we”) regarding the collection and use of your personal information. This Notice applies to personal information collected and used in connection with our public-facing corporate website and any other websites operated by GAP that link to this Notice (collectively, “Websites”). This includes email, phone and other communications with you in relation to the Websites and operation of our business generally. From time to time, we may update this Notice as we undertake new personal information practices or adopt new privacy policies. This Notice also does not apply to personal information shared by you with, or collected by, third parties whose websites may be accessed from a GAP Website through links to those third party websites.
Website visitors, and current and potential clients and service providers may provide us personal information. We also automatically collect information about Website visitors. We process this information to perform our contractual obligations or fulfill requests, to comply with our legal obligations and to pursue our legitimate interests. We share personal information with third parties that provide us services in the operation of our business. Depending on your jurisdiction, you may have rights regarding your personal information, including the right to access and update your personal information, and under certain conditions to erase it or transmit it to a third party, to restrict its processing and object to our use of your information and to request that we stop processing your personal information for direct marketing to you. If you wish to exercise your rights, or have any questions or requests concerning the processing of your personal information, please contact us at our contact information at the bottom of this Notice.
What information is collected?
What personal information we collect
We generally collect contact information (such as a person’s name, company or employer name, email address, mailing address, and phone number). This contact information is typically work contact information as we offer and provide our services to businesses, not to individuals.
We also collect technical data automatically when you visit our Websites such as your IP address, browser type and version, operating system, information about your activity on the Website including the date and time you access the Website and similar web server log information, as well as your indicated preferences in using our Website. Some of this information could be used to identify you or be associated with you.
How we process and protect your personal information
We collect information that you give us. Typically this is contact information for you and your company or employer that we collect directly from you, such as when you request information about our offerings via our Websites, subscribe to our newsletter or services, or provide us your contact information as a billing or vendor contact. In such instances, you generally decide how much information to share with us, but not providing this information may prevent us from fulfilling your request or otherwise performing the activity for which the information is collected.
We collect information automatically. By visiting and interacting with our Websites, we collect certain technical data by automated means such as your IP address, browser type and version, operating system, information about your activity on the Website, the date and time you access the Website, and your indicated preferences in using our Website.
Information from other sources. We may obtain information about you from other sources. For example, your employer as a customer of ours may provide us with your contact information as your employer’s billing contact or provide us your contact information as a recipient of our reports and other offerings for the customers’ account.
Purposes for processing your personal information
We rely on one or more of the following grounds in collecting and handling your personal information:
- to carry out GAP’s obligations under any contracts between a company with which you are affiliated, and GAP, including by providing services and support;
- to fulfill your request to provide you with GAP newsletters and other communications or information about GAP services (e.g., by email);
- to comply with a relevant legal obligation, such as keeping accounting records; and
- as necessary for the purposes of GAP’s legitimate interests to use service provider, client and Website user data to conduct and develop our business activities. Those purposes include:
- administering Websites, including for troubleshooting, data analysis, testing, research and statistical purposes (for further information regarding statistical purposes please the section below titled “Cookies”);
- displaying and customizing content on the Websites to you and your device;
- operating, evaluating, maintaining, improving and developing the Websites (including by monitoring and analyzing trends, access to, and use of the Website for advertising and marketing, for further information please the section below titled “Cookies”);
- evaluating, improving and developing our products and services generally;
- corresponding with users to resolve their queries or complaints;
- protecting and ensuring the security of the Websites, GAP networks and confidential and proprietary information, and GAP employees;
- managing, protecting against, and investigating fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations;
- sharing your personal information with third parties in connection with potential or actual sale of our company or any of our assets, or those of any affiliated company, in which case personal information held by us about our users may be one of the transferred assets;
- providing information on the Websites and via GAP newsletters and similar communications concerning GAP-related news, events, activities and other services; and/or
- to give you the opportunity to participate in interactive features of the Websites.
Legal basis for processing your personal information
Our legal basis for collecting and using your personal information will depend on the personal information concerned, the specific context in which we collect it, and the purposes for which it is used.
However, we will normally collect and use your personal information only where we have your consent to do so, where we need the personal information to create or perform a contract with you or your employer, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for most of our activities and purposes not covered by consent or creation or performance of a contract). In some very rare cases, we may also collect or use your personal information to protect your vital interests or those of another person.
If you have specific questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us via the information in the ‘Contact Us’ section at the end of this Notice.
Sharing your personal information with third parties
We do not sell or rent your personal information to any third party.
Where applicable, we share personal information in the follow ways:
- With our affiliated organizations (e.g. those under common control with us);
- With our partners, suppliers or agents involved in delivering or fulfilling the products and services our clients have procured from us;
- With service providers engaged to perform services for, or on behalf of us in our operations, including our marketing activities;
- With fraud-prevention, credit references, and business and credit scoring agencies;
- With debt collection agencies or other debt-recovery organizations;
- With law enforcement agencies, government bodies, regulatory organizations, courts or other public authorities if we have to, or are authorized to by law;
- To satisfy any applicable law, or other legal or regulatory requirement;
- With a third party with which we are engaged in an acquisition, merger, asset sale, or other similar business transfer that involves substantially all of our assets where personal information is transferred or shared as part of the business assets.
Retention of personal information
We will retain your personal information for the period necessary to fulfill the purposes outlined in this notice unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes.
We maintain reasonable and appropriate security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Our services and Website are not intended for or directed to children under the age of 16 and we do not knowingly collect information from children. If you believe we have collected information of a child, you can contact us at the information in the ‘Contact Us’ section at the end of this Notice.
Transfer of personal information to the US
GAP is headquartered in the United States and we have service providers in and outside the United States. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. GAP endeavors to apply suitable safeguards to protect the privacy and security of the personal information GAP processes and to use it only consistent with your relationship with GAP and the practices described in this Notice.
Here are the types of cookies you will encounter in using our Website:
- Strictly Necessary – these are required by the Websites to perform certain functions such as allowing users to log in to their web-based account;
- Functional – these help to improve your experience by doing things like remembering certain preferences you have set or optimizing the Website for your device;
- Analytic – these are used to analyze, in an aggregated manner, the way the Website is used so that we can improve the Website and our offerings. We use Google Analytics for this purpose.
Most Internet browser settings will allow you to accept, reject, delete and otherwise manage cookies. You can find more information about this at www.allaboutcookies.org. You can also avoid receiving cookies by browsing the Website using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, and “Private Browsing” in Firefox and Safari). Blocking our strictly necessary cookies will prevent certain functions of our website from working properly or at all. In addition to managing Google Analytics by managing its cookies, you can deactivate Google Analytics by using a browser plug-in found here.
Do not track requests
GAP does not track Website visitors when they cross to third party websites or provide targeted advertising to such visitors. Therefore, our Websites do not respond to Do Not Track (DNT) signals.
Your choices regarding your personal information
You may avoid our collection and use of manually submitted personal information by not providing it to us, although this may prevent us from providing products and services you request or purchase.
You may unsubscribe from our direct marketing communications by following the instructions or unsubscribe mechanism in the e-mail message or by contacting us at the contact information provided in the ‘Contact Us’ section of this Notice. Note, if you choose to opt out of marketing communications, we may still communicate with you for non-marketing transactional or administrative related purposes.
To the extent provided by the law of your jurisdiction, you may have the right to access or correct the personal information we maintain about you and, in some cases, you may require that we delete the information, or object to or request that we restrict our processing of the information. Such requests may be directed to us at the contact information in the ‘Contact Us’ section at the end of this Notice.
Additionally, you may have the right to lodge a complaint with your national Data Protection Authority or equivalent regulatory body depending upon your jurisdiction.
This Notice does not apply to, nor are we responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Websites link. This includes links to our pages on social media websites. The inclusion of such a link on our Websites does not imply our endorsement of or responsibility for the linked site or service.
Changes and updates to the Notice
As GAP’s services change from time to time, this Notice is expected to change as well. Please check our Websites frequently to see the current Notice that is in effect and any changes that may have been made to it.
You may contact us about matters pertaining to this notice at the following:
2448 Historic Decatur Rd. Suite 105
San Diego, CA 92106