This policy is divided into the following sections
A: Introduction/Purpose
B: Scope
C: Responsibility
D: Data Protection Principles
E: Uses of Personal Information
F: Purposes of Processing Personal Information
G: Legal Bases for Processing Personal Information
H: Data Subject Rights
I: Security
J: International Transfers of Personal Information
K: Disclosing Personal Information to Third Parties
L: Links and Third-Party Applications
M: Retention of Information
N: Queries and complaints
A: Introduction/Purpose
HiberCell collects, uses, and stores Personal Information about customers, suppliers, clients and other individuals who come into contact with us. We understand that Personal Information must be handled or processed in accordance with applicable Laws. In this regard our employees, consultants and other individuals who handle Personal Information on our behalf, are expected to comply with this Policy and applicable Laws.
This Privacy Policy applies to Personal Information handled or processed by HiberCell (“we”, “us” or “our”).
This Policy is not an exhaustive statement of all of our data handling practices. For example, we may apply specific policies within certain environments which, while consistent with this Policy, may contain certain variations. We might also include a particular privacy notice at the point of capturing Personal Information on a new service – any specific consents obtained, or information provided will apply to that service and will supplement this Privacy Policy. We may also introduce additional user choices on our platforms which will be clearly explained to users as required by applicable Laws.
All HiberCell staff
All HiberCell staff are responsible for complying with this Policy.
The Company
- HiberCell is responsible for processing of Personal Information
- HiberCell has designed business practices to align with applicable laws
- HiberCell has established systems to respond to queries, requests and threats to the protection of the Personal Information that is processed by third parties on our behalf
- HiberCell actively maintains, trains and audits its systems to ensure ongoing compliance with evolving laws and practices
- The nature of the Personal Information and the extent that a third party may be asked to process Personal Information on our behalf will vary according to the responsibilities of that third party. HiberCell will only share and receive Personal Information which is necessary to enable us and the relevant third party to perform our/their duties. In this context, information on current, past or prospective consultants, clients, may be processed.
When processing Personal Information, we comply with the following data protection principles:
- We obtain and Process Personal Information fairly
- We keep Personal Information only for one or more specified, explicit and lawful purposes
- We Process and disclose Personal Information only in ways which are compatible with these purposes
- We keep Personal Information safe and secure
- We keep Personal Information accurate, complete and, where appropriate, up-to-date
- We ensure that Personal Information is adequate, relevant and not excessive and
- We retain Personal Information for no longer than is necessary for the purposes for which we process it
E: Uses of Personal Information
HiberCell processes the following personal information:
HiberCell’s Website:
- Email addresses for replies to general information queries received through our website.
- Email addresses to process applications for employment
Suppliers, Collaborators and Customers:
- Personal details: name, title, position, work identification numbers, department, business unit, and contact details: address and phone number(s) work location.
F: Purposes of Processing Personal Information
HiberCell only uses Personal Information for the purpose(s) for which the Personal Information has been obtained.
The processing purposes are clearly specified, and the Individual(s) concerned will be informed about these purposes at the time of Personal Information collection or as soon as reasonably possible thereafter, and to the extent reasonably possible.
Some examples of the reasons for which HiberCell Processes Personal Information include, without limitation:
- relationship management
- marketing, PR, promotional activities and information provision concerning us and/or our services and products
- the improvement of our websites, services and products
- management information
- determining business strategy
- carrying out internal audits or investigations and the implementation of audit measures for internal management
- preventing and detecting unlawful and/or criminal behaviour directed towards us or our customers and employees, and preventing theft and/or fraud
- providing services to customers and
- fulfilling legal obligations
G: Legal Bases for Processing Personal Information
HiberCell only Processes Personal Information if one or more of the legitimate grounds set out below, which allow for compliant Processing of such Personal Information, apply:
Personal Information can be processed if the Individual concerned has given his or her consent (preferably in writing or via e-mail, or via the website personal cookie settings page). The consent relates to the specific purpose for which the Personal Information is required.
HiberCell ensures that Individuals are adequately informed about the Processing purposes before consent is requested. If there are multiple Processing purposes, separate consents may be required for each Processing type. The consent(s) provided are held on file as evidence of the consent(s) given.
Individuals may withdraw their consent to these types of Processing activities at any time directly for website usage via the personal cookie settings page.
This applies in relation to Processing of Personal Information necessary for the purposes of for example:
- accounts payable/accounts receivable, including any debt-collection process
- relationship management
- marketing, PR, promotional activities
Examples of our or a third party’s legitimate interest for Processing include, without limitation, carrying out regular business activities including:
- the improvement of, and communication about, our websites, services and products
- determining business strategy
- carrying out internal audits or investigations and the implementation of audit measures for internal management
- preventing and investigating theft or fraud and/or breach of HiberCell’s codes and policies, including possible legal offences, whether actual or suspected and/or
- guaranteeing rights, liberties, and/or the health or safety of our employees, contractors or third parties.
Such Processing may include, for example, the disclosure of Personal Information if demanded by the judiciary or a tax authority. Such Processing may also include Processing of Personal Information for anti-money laundering purposes.
Individuals have certain rights under applicable Laws, as explained below. The procedures below explain how Individuals’ rights are given effect, upon receipt of a written request or objection relating to the processing of their Personal Information by us:
Request for correction/addition/removal:
If Personal Information processed by us is believed to be inaccurate or incomplete, the Individual concerned is entitled to request that HiberCell take measures to have such Personal Information corrected, added to, protected or deleted.
Every Individual is entitled to object to the processing of his/her Personal Information based on the legitimate interests of HiberCell.
Security of Personal Information
- Through our policies, HiberCell has implemented a range of technical and organizational security measures to protect Personal Information from unlawful or unauthorized destruction, loss, change, disclosure, acquisition or access.
- HiberCell operates and encourages a culture of data privacy and security awareness supported by regular employee training, both at induction and throughout their employment.
- HiberCell ensures that all Personal Information controlled by us is held securely using appropriate security measures.
Personal Information Security Breach
- In the event of an Information Breach, HiberCell will comply with applicable Laws governing the reporting of such breaches and manage any Information Breach in accordance with our Incident Response policy.
- Our Incident Response policy is followed as soon as it is identified that a possible Information Breach has occurred.
J: International Transfers of Personal Information
HiberCell collects and receives Personal Information from inside and outside of the United States and complies with this Privacy Policy in relation to the processing of any such Personal Information.
Where HiberCell receives Personal Information from third party organisations located in the EU/EEA, HiberCell uses Standard Contractual Clauses as a legal mechanism for such data transfer (or such other European Commission approved data transfer mechanism as may be appropriate).
K: Disclosing Personal Information to Third Parties:
From time-to-time, HiberCell may disclose Personal Information to third parties or allow third parties to access Personal Information processed by us in accordance with applicable Laws.
Categories of third parties with whom HiberCell may share Personal Information includes service providers and research collaborators.
L: Links and Third Party Applications:
The HiberCell website contains hyperlinks to external social platforms. Clicking on any of these links will direct you to an independent, third-party website with its own privacy policy, and which may place its own third-party cookies on your device. HiberCell has no control over, and no responsibility or liability for, third-party websites that you may access via our website, or their collection, use and disclosure of your personal information through advertisement cookies or other technologies that you may encounter in connection with your use of such websites or third-party applications, please see our Cookies Policy below.
HiberCell keeps Personal Information of Individuals only as long as the Personal Information is adequate, relevant and limited to what is necessary in relation to the purposes for which that Personal Information has been collected.
To determine the appropriate retention period for Personal Information, HiberCell considers the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of such Personal Information, the purposes for which HiberCell processes Personal Information and whether HiberCell can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Any information that is no longer being used will be securely deleted.
HiberCell is committed to protecting Personal Information and processing Personal Information in compliance with applicable Laws. If Individuals wish, they can raise a query or make a complaint about compliance with this Policy by sending their complaint or query to: info@HiberCell.com
Should you wish to raise a query or make a complaint about compliance with our Personal Information processing practices, please contact us regarding any questions or concerns relating to HiberCell’s approach to protecting your information and we will consider your request in accordance with applicable laws.
HiberCell’s Cookies Policy
Cookies are small pieces of information or text files that allow us to make our website work properly and maintain your connection to our website. We use cookies in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media.
Some of these cookies enable the website to function and allow us to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
When you first visit our website, we set essential cookies required for website functionality on your device. Your continued use of our website means you consent to our use of these cookies.
How long will cookies stay on my device?
The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.
Third Party Cookies
HiberCell uses:
A persistent cookie for Google analytics to distinguish between humans and bots
More information is available here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
A number of cookies from LinkedIn – a session cookie to remember the users preferred language version of a website, a number of cookies to track the use of embedded services, a session cookie to track the embedded “follow us” panel and a 29-day cookie to track visitors from multiple websites in order to present relevant advertisements based on the visitor’s preferences.