Privacy Policy

The GDPR (General Data Protection Regulation) is an EU-wide privacy and data protection law that gives individuals more control over their personal data. It places certain obligations on businesses that process information of individuals.

We, at CMGi, embrace these changes, and have made a number of updates to our Privacy Policy, to comply with the transparency requirements under GDPR. We have also taken this opportunity to implement GDPR controls as our baseline standard for all our operations.

We have completely rewritten our Privacy Policy to provide more transparency and clarity about our practices. We have become stricter with our stand on privacy.

Last Updated: 16th of July 2019

This Security Statement applies to the products, services, websites provided by CMG Interactive Limited. We refer to those products, services, websites and apps collectively as the “Services” in this Statement. This Security Statement also forms part of the service contract agreements for CMGi customers.

CMGi values the trust that our customers place in us by letting us act as protectors of their data and ICT systems. We take our responsibility to protect and secure your information seriously and strive for complete transparency around our security practices detailed below. Our Privacy Policy also further details the ways we handle your data.

Physical Security and Compliance
CMGi's information systems and infrastructure are hosted within secured, world-class, ISO27001 accredited data centers within the European Union. Physical security controls at our data centers include 24x7 monitoring, cameras, visitor logs and entry requirements.

Access Control
Access to CMGi's technology resources is only permitted through secure connectivity (e.g., VPN, SSH) and requires multi-factor authentication. Our production password policy requires complexity, expiration, and lockout and disallows reuse. CMGi grants access on an as-needed basis, reviews permissions quarterly, and revokes access just prior to employee termination.

Security Policies
CMGi maintains and regularly reviews and updates its information security policies on an annual basis.

Personnel

CMGi conducts background screening at the time of hire (to the extent permitted or facilitated by applicable laws and countries). In addition, CMGi communicates its information security policies to all personnel, and requires new employees to sign employment agreements.

Vulnerability Management and Penetration Tests

CMGi maintains a documented vulnerability management program which includes periodic scans, identification, and remediation of security vulnerabilities on servers, workstations, network equipment, and applications. All networks, including test and production environments, are regularly scanned using trusted third party vendors. Critical patches are applied to servers on a priority basis and as appropriate for all other patches.

Encryption

We encrypt your data in transit using secure TLS cryptographic protocols.

Asset Management

CMGi maintains an asset management policy which includes identification, classification, retention, and disposal of information and assets. Company-issued devices are equipped with up-to-date antivirus software. Only company-issued devices are permitted to access corporate and production networks.

Information Security Incident Management

CMGi maintains security incident response policies and procedures covering the initial response, investigation, customer notification (no less than as required by applicable law), public communication, and remediation. These policies are reviewed regularly.

Breach Notification

Despite best efforts, no method of transmission over the Internet and no method of electronic storage is perfectly secure. We cannot guarantee absolute security. However, if CMGi learns of a security breach, we will notify affected users without undue delay and in-line with GDPR requirements, so that they can take appropriate protective steps. We are committed to keeping our customers fully informed of any matters relevant to the security of their account and to providing customers all information necessary for them to meet their own regulatory reporting obligations.

Business Continuity Management

CMGi's systems are backed up on a rotating basis of full and incremental backups and verified regularly. Backups are stored within the production environment to preserve their confidentiality and integrity and are tested regularly to ensure availability.

Your Responsibilities

Keeping your data secure also requires that you implement adequate security policies and controls to ensure the confidentiality, integrity and availability of your data and information systems. CMGi can assist is helping your organisation formulate and put in place, these policies and controls.

Last Updated: 16th of July 2019

1. Introduction

This Privacy Policy applies to all the products, services, websites offered by "CMGi", owned and operated by CMG Interactive Limited. (collectively “CMGi”, “us”, or “we”). We refer to those products, services, websites and apps collectively as the “Services” in this policy. References to "data" in this Privacy Policy will refer to whatever data you use our services to collect, or data inserted on one of our website – either or, it’s all your data. Reference to personal information or just information, means information about you personally that we collect or for which we act as protector. If you want to identify your data controller please see the "Who is my data controller" section below.

2. Information We Collect

2.1 Who are “you”?

We refer to “you” a lot in this Privacy Policy. To better understand what information is most relevant to you, see the following useful definitions.

Visitors
You are just visiting our website because you are curious, or might be interested in our services.
Creators
You created and hold a CMGi Customer Portal account, and are using our services to manage your IT Incident and Service Requests. Creators are data controllers.
Users
Your employer (“Creator”) created a Connectwise account, and you as an employee, may have a login to use our services for various reasons, such as submitting support requests, viewing your request history, viewing reports, or simply review and sign
an e-document.

IF YOU ARE AN EMPLOYEE OF A CUSTOMER THAT USES CMGI SERVICES, PLEASE ALSO REFER TO YOUR EMPLOYER’S PRIVACY POLICY, WHICH APPLIES TO THE COLLECTION, USE, PROCESSING AND RETENTION OF YOUR PERSONAL INFORMATION. EMPLOYEES OF OUR CUSTOMERS WHO SEEK ACCESS TO THEIR DATA, OR WHO SEEK TO UPDATE OR DELETE INACCURATE DATA SHOULD DIRECT THEIR REQUESTS TO THEIR EMPLOYERS WHO ARE CMGI CUSTOMERS.

2.2 Information we collect about you

Contact Information
You might provide us with your contact information, whether through use of our services, a form on our website, an interaction with our sales or customer support team.
Usage Information
We collect usage information about you whenever you interact with our websites and services. This includes which web pages you visit, what you click on, when you perform those actions, what language preference you have, and so on.
Device and browser data
We collect information from the devices you use to access our services. Device data mainly means your IP address, operating system version, serial number, MAC address, device type, system and performance information, all installed software. We do this by installing a small piece of software called Connectwise Control. This also provides us with Remote Access to your PC.
Information from page tags
CMGi and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different services and devices. We provide more information on cookies below and in our Cookies Policy.
Data logs
Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.

If you are a Creator we will also collect:
Registration information
When you register for a CMGi Customer Portal account, we collect a company name, your first and last name, a username, a password and an email address.
Billing information
If you make a payment to CMGi, we also store you bank details - BIC and IBAN, a name, address, email address and financial information corresponding to your selected method of payment. We do not store or process credit card information.
Account settings
You can set various preferences in your User Preferences page within the CMGi Customer Portal.
If you are a User:
Creators, who are your data controllers, and probably your employer, may have access to provide personal information in their CMGi Customer Portal account, on your behalf. Please refer to your employer’s privacy policy, which applies to the collection, use, processing and retention of your personal information.

3. How We Use The Information We Collect

3.1 Visitors

We process personal data about you where:

You have consented or;

CMGi has legitimate interests in:

Improving service experience; and

Developing new products and service features.

In each of the instances where we describe how we use your data in this privacy policy, we have identified which of these grounds for processing we are relying upon.

When you have consented we collect and use the following information about you:

Contact Information
We use contact information to respond to your inquiries, send you information as part of the services, and send you marketing information (as long as you have agreed to this at the point of providing your information and for as long as you do not opt-out).

Example: We provide your email address to a member of our sales team or customer success team who will contact you if you submitted an inquiry through one of the online forms on our site.
Cookies - page tags and web beacons
We collect information from page tags and web beacons to allow us to determine the success of our advertising campaigns. For more information please read our Cookies Policy.

Example: To personalize marketing campaigns run through third party advertisers and help CMGi measure online advertising success and to deliver ads for our services based on user preferences. See our cookies section. If you do not want CMGi to use this information to serve you targeted ads about our services, you may indicate your preferences at https://preferences-mgr.truste.com/ or, if you are located in the European Union, at https://www.youronlinechoices.eu/. You may continue to receive ads over the internet that are not based on information you provided to CMGi.
How you use our services
We use information about how you have interacted with our website to improve our services for you and all users.

Example: We collect information about the web pages you have visited and your activity on our website. We collect this information so that we can track the most visited and most useful parts of our website to identify what are our most popular services.

We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in this privacy policy. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used. Our primary goal is to improve our services, while also ensuring that personal information of all users is respected and protected.

Device data
We use device data both to troubleshoot problems with our service and to make improvements to it.

Example: We collect device and browser information from you to troubleshoot website functionality issues and to fix bugs.
Log data
We use log data for many different business purposes to include:

To monitor abuse and troubleshoot.
To fix bugs and troubleshoot product functionality.

Example: Your browser type to determine how we can present our website best within that browser environment.
To manage our services we will also internally use your information and data, for the following limited purposes:

To enforce our agreements where applicable.
To prevent potentially illegal activities.
To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud.
Legal uses

To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a legal request, we may need to inspect the data we hold to determine how to respond.

3.2 Creators

We process personal data about you either with your consent or in order to:

Fulfill our contractual responsibility to deliver the services to you;
To pursue CMGi's legitimate interests in:

Improving service experience; and

Developing new products and service features.

In each of the instances where we describe how we use your data in this privacy policy, we have identified which of these grounds for processing we are relying upon.

You have consented to us using certain types of cookies on our websites. In particular we use:

Cookies - page tags and web beacons
We collect information from page tags and web beacons to allow us to determine the success of our advertising campaigns. For more information please read our Cookies Policy.

Contact Information
We use contact information to respond to your inquiries, send you information as part of the services, and send you marketing information (for as long as you do not opt-out). We use your email address to send you marketing (newsletters), unless you indicate a preference to opt-out and for general updates on your account. You can opt out of marketing communications at any time by clicking on the “unsubscribe” link in them, or changing the relevant setting on your My Preferences page.
How you use our services
We use information about how you have interacted with our website to improve our services for you and all users.
Device data
We use device data both to troubleshoot problems with our service and to make improvements to it.
Log data
We use log data for many different business purposes to include:
To monitor abuse and troubleshoot.
To fix bugs and troubleshoot product functionality.
Third parties and integrations
We will collect and use information from third parties and integration partners to:

Ensure you can sign-up to our service from a third party integration like Facebook/LinkedIn/Microsoft/Google/SSO;

To personalize our services for you; and

Ensure you can use our service in conjunction with other services.

To manage our services we will also internally use your information and data, for the following limited purposes:
To enforce our agreements where applicable.
To prevent potentially illegal activities.
To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud.
Legal uses
To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a legal request, we may need to inspect the data we hold to determine how to respond.

3.3 Users

We process personal data about you either with your consent or in order to:

Fulfill our contractual responsibility to deliver the services to you;
To pursue CMGi's legitimate interests in:

Improving service experience; and

Developing new products and service features.

In each of the instances where we describe how we use your data in this privacy policy, we have identified which of these grounds for processing we are relying upon.

You have consented to us using certain types of cookies on our websites. In particular we use:

Cookies - page tags and web beacons
We collect information from page tags and web beacons to allow us to determine the success of our advertising campaigns. For more information please read our Cookies Policy.

Contact Information
We use contact information to respond to your inquiries, send you information as part of the services, and send you marketing information (for as long as you do not opt-out). We use your email address to send you marketing (newsletters), unless you indicate a preference to opt-out and for general updates on your account. You can opt out of marketing communications at any time by clicking on the “unsubscribe” link in them, or changing the relevant setting on your My Preferences page.
How you use our services
We use information about how you have interacted with our website to improve our services for you and all users.
Device data
We use device data both to troubleshoot problems with our service and to make improvements to it.
Log data
We use log data for many different business purposes to include:
To monitor abuse and troubleshoot.
To fix bugs and troubleshoot product functionality.
Third parties and integrations
We will collect and use information from third parties and integration partners to:

Ensure you can sign-up to our service from a third party integration like Facebook/LinkedIn/Microsoft/Google/SSO;

To personalize our services for you; and

Ensure you can use our service in conjunction with other services.

To manage our services we will also internally use your information and data, for the following limited purposes:
To enforce our agreements where applicable.
To prevent potentially illegal activities.
To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud.
Legal uses
To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a legal request, we may need to inspect the data we hold to determine how to respond.

4. Information We Share: Partners and Integrations

We do not share your personal indentifying data with third parties outside CMGi except in the following limited circumstances:

To help us provide certain aspects of our services we use trusted key partners – in particular, we engage third parties to provide platforms to:

Manage our sales and customer support services to you.
Deliver and help us track our marketing and advertising content.
Help us track website conversion success metrics.
Provide hosting, maintenance, backup, storage and virtual infrastructure.

We enter into confidentiality and data processing terms with partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards and we regularly review these standards and practices.

We also have to share information or data in order to:

Comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.
Enforce our agreements, policies and terms of service.
Protect the security or integrity of our products and services.
Protect against harm to the rights, property or safety of our users, the public or to CMGi and/or as required or permitted by law.

5. Cookies

We and our partners use cookies and similar technologies on our websites. For more information see our Cookies Policy.

6. Security

You can find everything related to how we tackle security by following the link.

7. Data Retention

If you are a Creator and hold an account with CMGi's Connectwise Portal, we do not delete the data in your account – you are responsible for and control the time periods for which you retain this data. There are controls in your account where you can delete data at a User level. A written request to delete data can also be sent to the following address:

Data Protection Officer
CMG Interactive Limited

8 Vergemount Hall

Clonskeagh Road

D06 TC53

Ireland

If you are a Creator, we also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

If you are a User (employee), you will need to ask the Creator (your data controller) how long your data will be stored in our services.

8. Safety of Minors

Our services are not intended for and may not be used by minors. “Minors” are individuals under the age of 13 (or under a higher age if permitted by the laws of their residence). CMGi does not collect personal data from Minors. If it comes to our attention that we have collected personal data from a Minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact our Service Desk.

9. Changes to our Privacy Policy

We may update this Privacy Policy from time to time, and will notify account holders of significant changes in the way we treat any personal information, by sending a notice to the primary email address specified in your CMGi Portal. We may also place a prominent notice on our website. We encourage you to periodically review this page for the latest information on our privacy practices.

10. Who Is My Data Controller?

Please contact your own internal Data Protecion Office to ascertain this. In the context of CMGi's services, your employer is your Data Controller.

11. Your Rights

Some of you (in particular, European Users) have certain legal rights to obtain information about whether we hold personal information about them, to access personal information we hold about them, and to obtain its correction, update, amendment or deletion in appropriate circumstances. If you seek to express any of the following rights, you should direct your request to your employer, who is a customer of ours. Your employer is able to delete and update personal information and data without our involvement.

Rights which you are entitled to are:

Data access rights

Right to restrict processing

Right of Rectification

Right to Erasure (Right to be Forgotten)

Right to object to processing

Right to withdraw consent; and

Data portability rights

11.1 Website Visitors

If you have visited our website and you want to exercise any of the above rights please contact our customer support team. Alternatively if your request is for the right to be forgotten as it relates only to our use of cookies you can achieve this by clearing the cookies in your browser settings.

12. Exercising Your Rights

Our contact information for privacy inquiries

CMG Interactive Limited
8 Vergemount Hall

Clonskeagh Road

D06 TC53

Ireland

dataprotection@cmgi.ie

Last Updated: 24 May 2018

What is a cookie?

A cookie is a small piece of data sent by a website's server to your computer or mobile device and stored in your browser (e.g. Google Chrome, Internet Explorer, Safari). It consists of anonymous information, including a unique user identifier. When you revisit a site or navigate between pages, this data is passed from your browser to the site's server. With this data, the website is able to 'remember' your browser, enabling it to retrieve your user preferences, to personalise your visits and to simplify any sign-in procedures.

Cookies are intended to improve your user experience by making it easier and faster to navigate through a website. For example, some websites require that you log in to gain access. If such sites did not use cookies, then you would be required to enter your login details every time you navigated to a new page because the website would not be able to remember that you had already logged in.

Many websites also use cookies for advertising purposes. For example, certain cookies allow a website to determine if you've already seen a particular ad and therefore it may not display that ad on subsequent pages that you visit.

All of the information a cookie collects can only be retrieved by the website server that sent the cookie to your browser.

CMGi's website uses small pieces of data called cookies to help us learn more about the traffic on our website. You can learn more about cookies and how you can control them by reading our Cookie Policy. We may update our Cookie Policy to reflect any changes in technology or data protection legislation. Any updates or changes that may affect how we use cookies or how you as a user can manage cookies will appear on this page.

Last Updated: 24 May 2018

Cookies on cmgi.ie

Strictly necessary cookies - These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies - They are set by cmgi.ie and third parties, including Google Analytics. Performance cookies allow us to collect statistical information about our visitors, such as whether they have visited the site before and the pages they view. This information is gathered anonymously - it does NOT enable us to identify who you are. We use these cookies to determine the kind of content and services our visitors value most, which in turn helps us improve our website and its content. Google Analytics is a website monitoring tool that allows users to see volumes of website visitors, their source, and to analyse how the content of their website is viewed and navigated. Visitors to our websites may opt out of certain types of Google Analytics tracking. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on : https://tools.google.com/dlpage/gaoptout
Third-party vendors - including Google, use first-party cookies and third-party cookies together to inform, optimise and serve ads based on users’ past visits to this website. We use data from Google's Interest-based advertising or 3rd-party audience data (such as age, gender and interests) with Google Analytics to understand who our users are in order to create a better experience for them while visiting our website. We may use Remarketing with Google Analytics to advertise online. Third-party vendors, including Google, show our ads on sites across the Internet.
Users can opt out of Google Analytics for Display Advertising and customise Google Display Network ads using the Ads Settings found here: www.google.com/settings/ads.
Functionality cookies - These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.
Targeting cookies - Some of the cookies set on our website are served by third parties and not directly related to CMGi. For example, occasionally you will find a page on cmgi.ie that includes a video embedded from YouTube. Service providers such as YouTube set their own cookies on your web browser. We do not control which cookies are set by third parties or how the cookie information is used - a cookie can only be accessed by the party who set it. For more information on these cookies, please visit the third-party website.
Controlling cookies - Cookies are meant to improve the user experience, but some users prefer to set restrictions on the types of cookies that can be stored on their computer or mobile phone. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies