Our privacy practices are consistent with:
- EU General Data Protection Regulation (GDPR)
In accordance with these laws, SG may share information, including Personal Information (as defined in section 5 below) provided on a voluntary basis with its promotion and marketing agency and mass-mailing agency.
All Personal Information is collected with your voluntary consent. Personal Information is not accessible to anyone outside the specific function for which it is collected. SG values the privacy of its customers, employees, job applicants and other visitors to its website who may choose to provide Personal Information.
Secure Group’s Commitment: Our Privacy Principles
Our commitment regarding your Personal Information is reflected in a series of 10 Privacy Principles, which are as follows:
1. Principle – Accountability
SG is responsible for Personal Information under its control.
2. Principle – Identifying the Purposes for Collection of Personal Information
3. Principle – Consent for Collection, Use, or Disclosure of Personal Information
SG will obtain your informed consent for the collection, use or disclosure of your Personal Information, except as permitted by law.
4. Principle – Limiting Collection of Personal Information
SG will limit the collection of personal information, both the amount and the type of information, to what is necessary for the purposes identified by SG.
5. Principle – Limiting Use, Disclosure and Retention of Personal Information
SG will not use or disclose Personal Information for purposes other than the identified purposes for which it was collected, except with your consent or as required or permitted by law. SG will retain your Personal Information only as long as necessary to fulfill the identified purposes.
6. Principle – Accuracy of Personal Information
SG will attempt to make sure that your Personal Information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
7. Principle – Security Safeguards
SG will protect your Personal Information by security safeguards appropriate to the sensitivity of the information.
8. Principle – Openness Concerning Policies and Practices
SG will make readily available to you specific information about our policies and practices relating to the management of Personal Information.
9. Principle – Individual Access to Personal Information
Upon written request, subject to certain exceptions, SG will inform you of the existence, use, and disclosure of your Personal Information and will give you access to that information. You are able to challenge the accuracy and completeness of the information and have it amended as appropriate.
10. Principle – Challenging Compliance
Consent to Share and Disclose Information
Consent to Electronic Notice if There is a Security Breach
- If SG is required to provide notice of unauthorized access of certain security systems, you agree that SG may do so when required or voluntarily by posting notice on the Website or sending notice to any email address that we have for you, at SG’s sole discretion. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.
Type of information we May Collect
- “Personal Information” is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.
- Personal Information shall include but is not limited to: name, home address, home postal code, home telephone number, mobile phone number, email address and employment related information such as may be found on resumes, applications, background verification information, or in employment references.
- Non-personal Information is information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and not subjected to special protection and it can be routinely shared with anyone inside or outside of the business. Business contact information shall include but is not limited to: business name, business address, business telephone number, and is not considered personal information in certain jurisdictions.
Internet Users – Cookies, Internet Protocol (IP) Address, Aggregate Information
- Cookies can expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer.
- Internet Protocol (IP) Address an Internet Protocol (IP) Address is associated with your computer’s connection to the internet. SG may use your IP address to help diagnose problems with SG’s servers, to administer the Website and to maintain contact with you as you navigate through the Website. Your computer’s IP address also may be used to provide you with information based upon your navigation through the Website. SG does not link IP addresses to any Personal Information.
- Aggregate Information €“ is used to measure the visitors’ interest in, and use of, various areas of the Website and the various services and programs that SG offers, SG will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, SG may undertake statistical and other summary analyses of the visitors’ behaviors and characteristics. Although SG may share this aggregate information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.
- We also use the services of Google analytics to gather Aggregate Information on our website. To opt out of being tracked by Google Analytics across all websites visit: tools.google.com/dlpage/gaoptout.
Our Use of Your Information
- With your prior consent, SG may market to you directly by email, mail or by telephone for the purposes, among others, of offering you some of SG new or current product. You may remove yourself from our list at any time.
- SG undertakes not to use any Personal Information it gathers in compliance with this policy or with any applicable legislation, to any other purposes unless we obtain your consent for that purpose or in certain exceptional circumstances, where we believe in good faith that the law requires or allows it.
Collection and Use of Customer Information
- SG will not collect Personal Information, unless you register for our services directly. In the future, and only to the extent that you expressly consented thereto, it is possible that we may use this information to contact you regarding products or promotions, as well as other products and services, which may be of interest to you. If you do provide us with Personal Information and expressly consent thereto, we may use the information to contact you, via e-mail, regular mail, telephone or other means, to provide you with information that you requested about specific products or services, provide additional future information about products or services that may be of interest to you, and to learn about and develop products and services. You may withdraw your consent at any time by unsubscribing from our database or contacting us in writing, as described below in the section 17.
This section applies to individuals who visit our Website through a mobile device such as cellphone or tablet computer:
1. Mobile Information We Collect
- Personally identifiable information (e.g. Name, email address) we collect only of what you share with us. For example, we may ask for this type of information so that we may contact you by phone or email at your request.
- If you use any location-enabled products, you may be sending us location information. SG does not store or use this information other than to provide the service you requested.
- Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve our customers through improved products, services, and revisions to the mobile applications. This collected information will not identify you to SG, it may however, let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country and language of download.
- Use of third party services such as social sharing sites (e.g., Facebook, Twitter, Google+, and Pinterest) is governed by the privacy practices of those services. SG does not capture or store your login information or other personally identifiable information for these services; however session info or cookies may be stored.
2. How We Use Mobile Collected Information
- We use the information collected through your mobile device to personalize your experience with the application and to improve your overall experience including the development of new products, services, and features. We also use the information to provide customer support, and when applicable, register and administer your account. Additionally, we may use the information you provide to contact you about updates to our service.
- Information you provide may be used to fulfill the service(s) or carry out the transaction(s) you have requested or authorized.
3. Except as Required by Law, SG Does Not Share Any Collected Mobile Information with Third Oarties With the Following Exceptions:
- SG may provide some personal data to third-party partners that are providing services essential to your mobile user experience.
- All requests are sent through your mobile carrier’s network and your carrier may have access to it. Consult your carrier’s privacy policies for additional information.
4. Opt-Out of Email and Mobile Updates
5. Sharing of Personal Information
- Although we make every effort to preserve user privacy, we reserve the right to disclose Personally Identifiable Information to a third party in certain limited circumstances, specifically: to comply with a law, regulation, search warrant, subpoena, judicial proceeding, a court order, or as otherwise may be required by law, to enforce our policies or contracts, to collect amounts owed to us, to protect users of our sites from fraudulent or abusive use, during emergencies when safety is at risk, as determined by us, or otherwise where necessary for the establishment, exercise or defense of legal claims. In addition, from time to time, server logs may be reviewed for security purposes; for example, to detect unauthorized activity on the Website. In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities. Such disclosures will be made in accordance with our Law Enforcement Guidelines.
- We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.
7. Storage, Retention and Accuracy of Personal Information
- SG takes all reasonable steps to insure that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.
- SG will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and your consent to such purpose(s) remains valid after termination of our relationship with you.
- We may store your Personal Information in our databases located in Montreal, Canada or in other datacenter outside Canada where they will be subject to the laws of the local jurisdiction. As a result, in certain circumstances, foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access the Personal Information collected and held by SG. We undertake to notify you using the email address contained in your account in the event of such disclosure.
8. Access, Control and Update Information About You
- We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. Therefore, whenever you believe that your Personal Information needs to be updated, you may use your account manager or you may contact us (see section 6) to update your contact information. You may choose at any time to remove your name, telephone numbers, and postal and email addresses from the lists we use to send notices or updates and elect not to receive correspondence from us also by contacting the Privacy Officer.
9. Links to Non-SG Web Sites and Third Parties
10. Social Media and Online Engagement
- We use a variety of new technologies and social media options to communicate and interact with consumers. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, we uses several third-party platforms including, but not limited to, Facebook, Twitter, Google+ and Pinterest. Third-Party Websites and Applications (TPWA) are Web-based technologies that are not exclusively operated or controlled by us. When interacting with our presence on those TPWA, you may reveal certain personal information to SG or to third parties. Except when used by our employees for the purpose of responding to a specific message or request, we will not use, share, or retain your Personal Information gathered through a TPWA.
- At this time, we are present on five (5) Social Media websites, Facebook.com/Securegroup, Twitter.com/ thesecuregroup, plus.google.com/+SecureGroup/, www.youtube.com/user/TheSecuregroup and pinterest.com/securegroup/
11. Our Privacy Officer
- You may contact our Privacy Office to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact the appropriate employee to fulfill your request.
- Should you have any questions or complaints, do not hesitate to contact the Privacy Officer. The Privacy Officer may be reached:
By phone at:
By mail at:
Attention: Secure Group Technologies Privacy Officer
13B Tintyava str., fl. 6, Izgrev Region, city of Sofia 1113, Republic of Bulgaria
By facsimile at:
- Should you have any questions or complaints, do not hesitate to contact the Privacy Officer. The Privacy Officer may be reached:
13. Terms and Conditions of Website Use