Last Updated: May 11, 2023
SCOPE OF THIS PRIVACY STATEMENT
RMSI Private Limited, and its affiliated companies and subsidiaries (collectively, “RMSI”) respect your privacy. This Privacy Statement applies to personal data collected by RMSI through this webpage/link/portal/campaign (as the case may be), and other websites which we operate and on which we post a direct link to this Privacy Statement. For some websites managed by RMSI affiliates, the affiliate may act as a controller for data collected from the website. This Privacy Statement may not apply to open-source project websites sponsored by RMSI. Such project websites may have their own privacy statements, which we encourage you to review.
Please also note that co-branded websites (websites where RMSI presents content together with one or more of our business partners) may be governed by additional or different privacy statements. Please refer to the privacy statement on those websites for more information about applicable privacy practices.
As used in this Privacy Statement, “personal data” means any information that relates to, is capable of being associated with, describes, or could be linked to, an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
For the purpose of this Policy and to ensure compliance with respect to GDPR Regulations, Data Protection Legislation means the Data Protection Act 2018 (DPA2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003, all the foregoing as amended from time to time, and any legislation implemented in connection with the aforementioned legislation. Where data is processed by a controller or processor established in the European Union or comprises the data of people in the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time.
In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.
RMSI’s leadership is fully committed to ensuring continued and effective implementation of this policy and expects all RMSI employees share in this commitment. Any breach of this policy will be taken seriously and may result in disciplinary action.
This policy has been approved by the Chief Executive Officer of RMSI.
THE CATEGORIES OF PERSONAL DATA WE COLLECT
To the extent permitted by applicable laws, the categories and types of personal data collected directly from you may include, without limitation:
- Contact information, including identifiers: Information used to communicate with you, such as first and last name, title, company name, email address, telephone number, and postal address;
- Account and commercial information: Information that RMSI maintains in association with your account, such as your account number, username/user ID, password, payment information, purchase records, information about your use of the product or service, information about your registration or participation in a class, exam, certification, training, webcast or other event, your preferred language and other preferences, credit and billing status and support inquiries;
- Professional or employment-related information: Information contained in your job inquiries or applications, such as resume, cover letter, age, education, professional history and contact details;
- Location information: Information about your physical location, such as if you provide your postal address or based on your IP address if you visit a website; and
- Inferences: Information drawn from the personal data collected above, such as what topics you may be interested in based on the areas of the website you visit or what products you may be interested in based on purchase records.
HOW WE COLLECT PERSONAL DATA (SOURCES OF DATA)
RMSI collects personal data directly from you and from other categories of sources as described in more detail below. The categories of personal data collected directly from you by RMSI include all of the categories identified above in “The Categories of Personal Data We Collect” section. RMSI collects personal data directly from you when you interact with us through our websites, including, without
- Create a user account (individual or corporate);
- Make online purchases or register products;
- Request support;
- Participate in surveys or evaluations;
- Participate in promotions, contests, or giveaways;
- Apply for employment;
- Submit questions or comments; or
- Submit content or posts on our customer portal pages or other interactive webpages.
HOW WE USE (PROCESS) YOUR PERSONAL DATA
RMSI may use personal data we collect about you to:
- Identify and Authenticate You. We use your personal data to verify your identity when you access and use our services and to ensure the security of your personal data. This includes your creation of an account that is associated with your personal data.
- The personal data that may be collected and processed for this purpose includes: name, title, company name, email address, telephone number, postal address, account number, username/user ID, password, preferred language and preferences. We process this information in order to comply with our contractual obligations to you. In other cases, it is in our legitimate business interests to be able to identify and authenticate
- Fulfill Your Requests. If you request something from RMSI, such as a product or service, a call back, a newsletter subscription, or specific marketing or other materials, we use the personal data you provide to respond to your request. We or our representatives may also contact you as part of customer satisfaction surveys or for market research purposes. Where required by applicable law, we will obtain your consent before sending marketing messages.
- The personal data that may be collected and processed for this purpose includes: name, title, company name, email address, telephone number, postal address, account number, username/user ID, payment information, purchase records, information about your use of the product or service, information about your registration or participation in an event, your preferred language and other preferences, credit and billing status, and support inquiries. We process this information in order to comply with our contractual obligations to you when responding to your requests. In other cases it is in our legitimate business interests to be able to provide customers and prospective customers with information, goods, or services they request.
- Provide You with Information About Our Products, Services and Events. RMSI may use your personal data to notify you about product and service offerings as well as events that we believe may be of interest to you. RMSI also may use your personal data to respond directly to your requests for information, including registrations for newsletters or other specific requests.
- The personal data that may be collected and processed for this purpose includes: name, title, company name, email address, telephone number, postal address, account number, username/user ID, payment information, purchase records, information about your use of the product or service, information about your registration or participation in an event, your language and other preferences, credit and billing status, and support inquiries and location information and inferences. It is in our legitimate business interests to be able to provide customers, prospective customers, and the public with information about our products, services, and events.
- Enhance the Website Experience. When you use our websites and/or respond to our emails, we use the personal data you provide for the purpose of enhancing and customizing your experience on our websites and to deliver content and product and service offerings relevant to your interests, including targeted offers through our website, third-party sites or email (with your consent, where required by applicable law). We may also use this information to help us improve and further develop our websites, products and services.
- The personal data that may be collected, shared and/or processed for this purpose includes: name, title, company name, email address, telephone number, postal address, information about your use of the product or service, information about your registration or participation in an event, your preferred language and other preferences, location information, inferences, information collected when you visit a website, such as IP address, browsing history, information on your interaction with the website, browser type and language, operating system, location, date and time. It is in our legitimate business interests to improve the RMSI websites, products and services and to enhance our users’ experience with the websites, products and services.
We will not use your personal data in a manner that is inconsistent with the purpose of its original collection, unless we have provided you additional notice and you have consented.
RMSI will retain your personal data for as long as is required to fulfill the purposes for which the information is processed or for other valid reasons to retain your personal information (for example to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements and for the establishment, exercise or defense of legal claims).
HOW WE DISCLOSE (SHARE) YOUR PERSONAL DATA
RMSI discloses personal data for the following business purposes:
- RMSI may disclose personal data to business partners and service providers in order to support our business operations, such as (but not limited to) fulfilling your orders, following up on requests, providing support and assisting RMSI with sales, marketing and communication initiatives. These business partners and service providers include distributors, resellers, payment processors, financial service providers and institutions, materials production and shipping companies, postal or government authorities, market intelligence and consulting service providers, and information technology service providers. Business partners and service providers are required by contract to keep the information received on behalf of RMSI confidential and secure and not use it for any purpose other than the purpose for which it was provided to them.
- The categories of personal data we may disclose to these third parties include: contact information, including identifiers; account and commercial information; professional or employment-related information; internet or other similar network activity; location information; and inferences.
- RMSI may disclose personal data as required by law or legal process, such as responding to a duly authorized and lawful request of a police or public authority (including to meet national security or law enforcement requirements), to enforce or protect the rights of RMSI, when such disclosure is necessary or appropriate to prevent physical harm or financial loss as permitted by applicable law, or in connection with an investigation of suspected or actual illegal activity.
- The categories of personal data we may disclose to these third parties include: contact information, including identifiers; account and commercial information; professional or employment-related information; internet or other similar network activity; location information; and inferences.
- RMSI may disclose personal data in the context of a business transaction involving part or all of RMSI, such as a merger, acquisition, consolidation, or divestiture. Such a transaction may involve the disclosure of personal data to prospective or actual purchasers, or the receipt of it from sellers. It is RMSI’s practice to seek appropriate protection for information in these types of transactions. Following such a business transaction, you may contact the entity to which we transferred your personal data with any inquiries concerning the use of that information.
- The categories of personal data we may disclose to these third parties include: contact information, including identifiers; account and commercial information; professional or employment-related information; internet or other similar network activity; location information; and inferences.
SECURITY
RMSI intends to protect your personal data. We have implemented appropriate physical, administrative and technical safeguards to help us protect your personal data from unauthorized access, use and disclosure. We also require that our business partners and service providers protect such information from unauthorized access, use and disclosure.
SOCIAL MEDIA, PUBLIC FORUMS AND LINKS TO OTHER WEBSITES
RMSI may provide social media features that enable you to share information with your social networks and interact with RMSI on various social media websites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media websites with which you interact to make sure you understand the information that may be collected, used, and shared by those websites.
Our websites may contain links to other websites. RMSI does not control and is not responsible for the information collected by websites that can be reached through links from our websites. If you have questions about the data collection procedures of linked websites, please contact the organizations that operate those websites directly.
DATA TRANSFERS AND PRIVACY SHIELD FRAMEWORKS
RMSI is a global organization, with legal entities, business processes, and technical systems that operate across borders. RMSI may transfer your personal data to other RMSI entities elsewhere. The United States and other countries may not have the same data protection laws as the country from which you initially provided the information.
Where required by applicable law, we have put in place appropriate safeguards (such as standard contractual clauses approved by the European Commission) in accordance with applicable legal requirements to ensure that your data is adequately protected. When transferring your personal data internationally, RMSI will protect your personal data as provided in this Privacy Statement.
CHANGES TO THIS PRIVACY STATEMENT
RMSI reserves the right to make corrections, changes or amendments to this Privacy Statement at any time. The revised Privacy Statement will be posted on this website. A notice will be posted on our homepage for 30 days whenever this Privacy Statement is changed in a material way, and the date of last update will be indicated at the top of the Privacy Statement. If you do not refuse the changes in writing within that notice period and you continue to use our websites, we consider that you have read and understand the Privacy Statement as changed, including with respect to personal data provided to us prior to the changes in the Privacy Statement. We encourage you to periodically review this Privacy Statement for any changes or updates.
REPORTING BREACHES
Any breach of this policy or of data protection laws must be reported as soon as practically possible. This means as soon as you have become aware of a breach. For externally reportable breaches, RMSI has a legal obligation to report the data breach to DPO within 72 hours.
All members of staff have an obligation to report actual or potential data protection compliance failures. This allows us to:
- Investigate the failure and take remedial steps if necessary
- Maintain a register of compliance failures
- Notify the DPO of any compliance failures that are material either in their own right or as part of a pattern of failures
Any member of staff who fails to notify of a breach, or is found to have known or suspected a breach has occurred but has not followed the correct reporting procedures will be liable to disciplinary action.
Please refer to our DPO at dpo@rmsi.com for our reporting procedure.
INDIVIDUAL RIGHTS REQUEST
You have various rights like right to be informed, right to access, right to withdraw consent, right to rectification, right to object, right to data portability, right to deletion or removal, right to damages, transmissibility of data subject rights, to a decision based solely on automated processing rights regarding the way RMSI holds personal data.
- Right to be informed. You have the right to be informed that your personal data will be, is being or was collected and processed by RMSI.
- Right to access. You may contact us to get confirmation that we are processing your personal data and request that we provide you with a written description of information that we have about you as well as the purpose for holding or processing the information.
- Right to withdraw consent. If our processing of your personal data is based on your consent, you may withdraw the consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful basis for processing it other than consent.
- Right to rectification. You have the right to have inaccurate or incomplete personal data we store about you rectified or completed. If such personal data has been disclosed to a third party in accordance with this Privacy Statement, then we shall also ask them to rectify or update your personal data.
- Right to object. If our processing of your personal data is based on our legitimate interests in operating, maintaining and developing our business, you have the right to object at any time to our processing. We shall then no longer process your personal data unless there are other compelling legitimate grounds for our processing that override your interests, rights and freedom, such as legal claims or obligations.
- Right to data portability. You have the right to receive your personal data from us in a structured, commonly used and machine-readable format and to independently transmit the data to a third party, if the processing is based on your consent and carried out by automated means.
- Right to deletion or removal. You have the right to have personal data we process about you deleted or removed from our systems if the personal data is no longer necessary for the purposes specified in this Privacy Statement. Upon your request, we will also delete data when you withdraw your consent or object to our processing of it, unless we have a legitimate basis for not doing so. We may not immediately be able to remove all residual copies from our servers and backup systems after the active data has been deleted. Such copies shall be deleted as soon as reasonably possible.
We reserve the right to request additional information necessary to confirm your identity. We may also reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
If you wish to exercise these rights, please download and complete our individual rights form and send it to DPO@rmsi.com first and if asked to send hardcopies of documentary proofs then you can send them at following address:
The Data Privacy Officer
RMSI Private Limited
A-8, Sector 16,
Noida – 201301
India
We may also decline to grant a request where doing so would undermine our legitimate use of data for anti-fraud and security purposes, such as when you request deletion of an information that is being investigated for security apprehensions. Other reasons your privacy request may be denied are if it risks the privacy of related to others, is playful or troublesome, or would be extremely impractical.
You have the right to report to your local Authority if you believe your rights under data protection legislation have not been appropriately considered. However, before doing so, please contact us directly as we are committed to working with you to help resolve any concerns about your privacy.
HOW TO CONTACT US
If you have any questions about RMSI’s privacy practices or use of your personal data, please feel free to contact us at dpo@rmsi.com, or by mail at:
RMSI Private Limited,
A-8 Sector 16,
Noida 201 301, India.