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We will use your personal data when the law allows us to. Most commonly, we will process your personal data in the following circumstances:

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Where you consent or Where it is necessary for our legitimate interests (i.e., we have a business or commercial reason for using your information) and your interests and your fundamental rights do not override those interests.

Our legitimate interests may include:

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• Providing high quality customer service

• Complying with laws or regulations that apply to us

• Seeking your consent when we need it to contact you

• Developing our products and services, and what we charge for them

• Defining customers for our products and services

• Providing our customers with relevant marketing, and other high quality product and service features

• Keeping our marketing updated and relevant.

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Change of Legal basis

We will only use your personal data for the uses and purposes set out above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original uses and purposes. If we need to use your personal data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so.

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Failure to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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Profiling

 We will not use your personal data for decisions based solely on automated processing if the decision has legal effects concerning you or if it significantly affects you, unless you gave your explicit consent for this processing.

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Third Party Access to Information

Segami uses certain trusted third parties (for example ShareFile from Citrix) to help us provide, improve, protect and promote our products and services. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy and we will remain responsible for their handling of your information per our instructions.

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International Data Transfers

Segami is owned and operated within the United States. Therefore, any data we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).

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Security

We are committed to ensuring that your personal data is secure. To prevent unauthorized access or disclosure, we have put appropriate technical and organizational measures in place to safeguard and secure your personal data.

If a data breach does occur, we will do everything in our power to limit the damage. In case of a high-risk data breach, and depending on the circumstances, we will inform you about remedial actions to prevent any further damage. We will also inform the relevant supervisory authority or authorities of the breach.

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Unfortunately, no security measures are completely secure. We therefore cannot guarantee that your personal data will not be disclosed, misused or lost by accident or by the unauthorized acts of others. Further, we cannot control dissemination of personal data you post in the public domain and you should have no expectation of privacy in respect of such data.

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Employees and temporary workers are required to follow policies and procedures and complete confidentiality training to understand the requirement of maintaining the confidentiality of customer information. If they fail to do so, they are subject to disciplinary action. All employees are required to complete privacy, security, ethics and compliance training. We also offer a wide variety of other training to all employees and temporary workers to help us achieve our goal of protecting your personal data.

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Data Retention

We retain your personal data for as long as your account is still open. We retain the personal data you provide while your account is in existence or as needed to provide you services. Even if you only use our services every few years, we will retain your information and keep your profile open until you decide to close your account. However, it may not always be possible to completely remove or delete all your personal data from our data bases without some residual data because of backups and other reasons.

 

To determine the appropriate retention period for the information we collect from you, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the data, whether we can achieve those purposes through other means, and the applicable legal requirements.

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