Date Last Revised: August 27, 2021
This supplemental privacy notice (“Privacy Notice”) provides European Economic Area (“EEA”) individuals additional information required by the EU General Data Protection Regulation. These provisions, together with the statements in the Maestro Privacy Statement (“Privacy Statement”), set forth our practices with regard to EEA personal data. For EEA individuals, if there is a conflict between this Privacy Notice and the Privacy Statement, this Privacy Notice governs.
This Privacy Notice sets forth our reasons for processing your personal information. Certain capitalized terms used but not defined in this Privacy Notice shall have the meanings set forth in our Privacy Statement.
Legal basis and purposes for data processing:
We only process your personal data when we have a legal basis for doing so. Specifically, we will only process your personal data as follows:
- Where our use of your personal data is within our legitimate interests or the legitimate interests of the organization with which we have shared your personal data and we have made sure that your personal data, and your rights in relation to that information, are protected. For example, we will collect your personal data for our direct marketing purposes in connection with the Sites and to further a direct relationship that we have with you as our client, including for the purposes of communication or completing transactions requested by you. Other legitimate business purposes for which we process your personal data include:
- Where the processing enables us to enhance, modify, personalize or otherwise improve our services/communications for the benefit of our customers;
- To identify and prevent fraud;
- To enhance the security of our network and information systems;
- To better understand how people interact with our Sites; and
- To determine the effectiveness of promotional campaigns and advertising.
Such processing pursuant to legitimate interests include, but is not limited to, disclosing your personal information to certain third-party vendors to further these interests, including third parties Google LLC, HubSpot, Inc., ZoomInfo Technologies LLC, Greenhouse Software Inc., WP Engine Inc., and Reply App Inc. Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regard and take account of those rights. You have the right to object to this processing if you wish, and if you wish to do so please contact us at email@example.com or by any via our toll-free number, 800.319.2122. Please bear in mind that if you object this may affect our ability to carry out the tasks identified above for your benefit.
- Where our use of your personal data is necessary to perform a contract or contracts that you are a party to, or to take steps that you request before entering a contract.
- Where we believe it is necessary to use your personal data to comply with a legal or regulatory obligation.
- In limited circumstances where we believe it is necessary to protect someone’s safety or vital interests;
- In certain circumstances, we may need to use your personal data for purposes which are in the public interest; and
- Where we have your consent. We will rely on your consent to, for example, use your personal data for marketing to you by email and text message. Where we rely on consent to use your personal data, you have the right to withdraw that consent at any time. Please see the ‘Your rights’ section of this notice for more details.
Automated decision making and profiling:
We do make automated-decisions about you or engage in data profiling. Specifically, decisions that you make to receive information about certain products may be used as an automated basis to send correspondence regarding similar subjects to you.
Personal information requirements:
You are not required to provide any personal information to Maestro. If you engage or access our services, you are required to provide certain personal information to enable us to perform the services. During your registration for our services, you will be provided with information regarding which data elements are required.
You have choices regarding how we use your personal information. You are entitled to the following:
The right to access: You have the right to request copies of your personal information. We may charge you a minor fee for this service.
The right to rectification: You have the right to request that we correct any information that you believe is inaccurate. You also have the right to request that we complete information that you believe is incomplete.
The right to erasure: You have the right to request that we erase your personal information under certain conditions.
The right to object to processing: You have the right to object to our processing of your personal information, under certain conditions.
The right to data portability: You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.
In addition, when Maestro provides its services or acts as a data processor, we receive your personal information from third parties as needed to provide services. If Maestro is processing your personal information as a data processor, we will refer you to our client for assistance with these requests. We support our clients with responding to requests required by law.
You may also decline our marketing communications.
To exercise these rights, please contact us via email to firstname.lastname@example.org or write to the address above. Note that for your protection, we may need to verify your identity before we can process your request.
If you believe that we have violated applicable law in our processing of your personal information, please contact us at email@example.com or a supervisory authority.
Cross-Border Data Transfers
Your personal information may be transferred to, stored at, or processed in the United States or other countries that may not have equivalent privacy or data protection laws.
Because the European Union Commission has determined that certain countries’ data privacy laws, including the United States, do not ensure an adequate level of protection for personal data collected from EU data subjects, any such transfers by Maestro to third parties having locations in these countries will generally be subject to appropriate additional safeguards under standard data protection clauses adopted by the EU Commission or adopted by a supervisory authority and approved by the EU Commission. You can obtain a copy of the standard contractual clauses by contacting us at firstname.lastname@example.org.
Your personal information will be retained for as long as the information is needed for the purposes set forth in our Privacy Statement and this supplemental Privacy Notice and for any additional period that may be required or permitted by law. The retention period depends on the purpose(s) for which the data was collected, how it is used, and applicable law. You may request that we delete your personal information by contacting us via email at email@example.com or writing to us at the address above. If we do not have a legal basis for retaining your information, we will delete it as required by applicable law.
Changes to Our Privacy Statement
It is our policy to post any changes we make to our Privacy Statement on our Sites. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account associated with the Sites, if any, or through a notice on the Sites’ home pages, and will seek your consent to such changes. The date the Privacy Statement was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Sites and this Privacy Statement to check for any changes.
If you have questions regarding this Privacy Statement or our data privacy practices, or if you believe we may have violated applicable law, please contact us at firstname.lastname@example.org or via our toll-free number, 800.319.2122.