Kigen global privacy statement

Last updated: [October 12,] 2020


Introduction

This Kigen Privacy Statement (“Privacy Statement“) describes our privacy practices. Please read this Privacy Statement carefully to learn how we collect, use, share and otherwise process information relating to individuals (“Personal Data“), and to learn about your rights and choices regarding our processing of your Personal Data.

A reference to “Kigen”, “we,” “us” or the “Company” is a reference to Kigen Ltd, an Arm Company, of 110 Fulbourn Road, Cambridge CB1 9NJ, UK.

Scope

Kigen is the controller of your Personal Data as described in this Privacy Statement.

For the avoidance of doubt, this Privacy Statement does not apply to the extent we process Personal Data in the role of a processor on behalf of our customers, including where we offer to our customers various cloud products and services.

Types of processing activities

This Privacy Statement applies to the processing of Personal Data collected by us when you:

Personal data we collect

  1. Directly from you

The Personal Data that we collect directly from you includes the following:

If you provide us with any Personal Data relating to other individuals, you must explain to those individuals that their Personal Data will be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or if you otherwise wish to exercise your rights relating to your Personal Data, please contact us by using the information set out in the “Contact Us” section below.

  1. From other sources

We also collect information about you from other sources and combine this information with Personal Data provided by you. This helps us to update, expand and analyze our records, identify new customers and create more tailored advertising to provide services that may be of interest to you. In particular, we collect Personal Data from third party providers of business contact information, including professional contact details, employment-related information (such as job titles) and device / location-related information (such as IP addresses) for purposes of targeted advertising, delivering relevant email content, event promotion and profiling.

We obtain information through partners, vendors, suppliers and other third parties. These enterprises largely fall into the following categories: partners, hosts or vendors at events or trade shows, research partners and enterprises that deploy the Kigen technology or third-party offerings that include Kigen technology. We might also obtain information through a partner as part of our business operations. This kind of data is used for work such as improving algorithms and data models, product testing and improvement, enhancing existing products and developing new capabilities and features.

Device and usage data

We use common information-gathering tools, such as cookies, web beacons and similar technologies, to automatically collect information that may contain Personal Data from your computer or mobile device as you navigate our websites, our services or interact with emails we have sent to you.

We gather certain information automatically in connection with the use of our website by individual users. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage.

In addition, we gather certain information automatically as part of your use of the cloud products and services. This information may include the information described in the preceding paragraph.

This device and usage data is primarily used for the purposes of identifying the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual (e.g., by means of an obvious identifier, such as a name) for security purposes or as required as part of our provision of the services to our customers (where we act as a processor). In any event, device and usage data will constitute your Personal Data.

Why and how we use your information

We collect and process your Personal Data for the purposes and on the legal bases identified in the following:

Where we need to collect and process Personal Data by law, or under a contract we have entered or will enter into with you, and you fail to provide the required Personal Data when requested, we may be unable to perform our contract with you.

When and how can Kigen share your personal data?

Sharing with third parties

We share information with the following third parties:

Sharing within Kigen

We share your information across the Kigen corporate group in order to provide, maintain and develop our products and services. Kigen employees will only access the information to the extent necessary to achieve the particular purpose(s) and perform their job.

We also share information that is not Personal Data, such as anonymized or aggregated information, for purposes such as analysis, identifying trends in the areas of our products and to help research and develop new Kigen services.

Data aggregation and analytics

We collate your Personal Data which you provide to us or we collect and use it anonymously for analytics, benchmarking and to effectively monitor our website and improve your user experience.

How long do we retain your information for?

We retain Personal Data for the period necessary to:

Retention periods can vary significantly based on the type of information and how it is used and our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our Kigen intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When Personal Data is removed from our systems, it will be deleted or destroyed using appropriate security protocols so that it cannot be reconstructed or read.

If you are located in a European Union Member State and certain other countries, you have the following additional rights:

Access and / or have your information provided to you

You can request a copy of the Personal Data we are processing about you.

Change or correct

You can ask us to change, fix or update information about you (for example, if it is incomplete or inaccurate).

Deletion 

You can ask us to delete Personal Data about you.

Restrictor limit use

You have the right to restrict our processing (i.e., stop any active processing) of your Personal Data (for example, if the information about you is inaccurate).

Portability 

In certain circumstances, you have the right to obtain Personal Data we hold about you in a structured, electronic format, and to transmit such data to another data controller.

Object

You have the right to object to Kigen using your Personal Data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). See below for information about how to unsubscribe to direct marketing.

Opt-out

You can withdraw your consent, including for marketing messages that you receive from us.

Please note that these rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority as described below.

Make a Data Subject Access Request

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the CCPA Privacy Statement.

International transfer of personal data

Your Personal Data may be collected, transferred to and stored by us in the United States and by our affiliates and third parties disclosed above, that are based in other countries.

Therefore, your Personal Data may be processed outside your jurisdiction, and in countries that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area (EEA). We ensure that the recipient of your Personal Data offers an adequate level of protection, for instance by entering into the appropriate data processing agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR).

Children’s privacy

We will not knowingly collect Personal Data from children under the age of 13 years. On occasion Kigen does run campaigns to encourage the use of technology for children under the age of 13. Such campaigns are strictly for educational purposes only. Any information collected by Kigen of participating children under the age of 13 is done with the consent of the parent or legal guardian and the data collected is strictly segregated and deleted immediately after the end of any such campaign.

Changes

We may modify this Privacy Statement at any time. If we make changes to this Privacy Statement, then we will post an updated version of this Privacy Statement on our website. We will specifically notify you by email about any material changes to this Privacy Statement.

Contact Us

If you believe we have used your Personal Data in a way that is not consistent with this Privacy Statement or your choices, or if you have any questions or comments about this Privacy Statement, please contact the Kigen Privacy Office at by emailing here: privacy[at]arm[dot]com. Any request will be evaluated and completed in accordance with applicable data protection law, including verification of the requestor’s identity.

Alternatively, please contact us at the following address:

Privacy Counsel
Kigen Limited – an Arm company
110 Fulbourn Road
Cambridge
CB1 9NJ

Filing a complaint

If you have a complaint about this Privacy Statement or any element of how we use your Personal Data, then please contact us first. If you are not satisfied and are located in a European Union country, then please contact your local data protection authority. If you are based in, or the issue relates to, the UK, you can contact the Information Commissioner’s Office at the following address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Alternatively, you can use an online form via the Information Commissioner’s website (https://ico.org.uk/concerns).

If you are based in, or the issue you would to complain about took place elsewhere in the EEA, please visit this website (http://ec.europa.eu/newsroom/article29/document.cfm?action=display&doc_id=50061) for a list of local data protection authorities in other EEA countries.

Last updated: October 12, 2020, SP-LES-PRE-20809 Version: 1.06,

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