Privacy Policy

Iceberg Benchmarking Platform by Caresoft Global Limited.

Effective: August 2021

Iceberg Benchmarking Platform (the "Site") is owned and operated by Caresoft Global Limited. (“ Caresoft”) .

Caresoft is the data controller.

Purpose The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Site of the following:

• The personal data we will collect;
• Use of collected data;
• Who has access to the data collected;
• The rights of Site users;
• The Site's cookie policy.

This Privacy Policy applies in addition to the terms and conditions of our Site.

GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

Consent
By using our Site, users agree that they consent to:

• The conditions set out in this Privacy Policy.

Legal Basis for Processing We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal basis to collect and process the personal data of users in the EU:

• Processing of user personal data is necessary for us to take, at the request of a user, steps before entering a contract or for the performance of a contract to which a user is a party. If a user does not provide the personal data necessary to perform a contract, the consequences are as follows: Access to the system may be deficient or disabled.

Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected Automatically When you visit and use our Site, we may automatically collect and store the following information:

• IP address
• Location
• Clicked links
• User behaviour such as Downloads of Assets such as but not limited to PDF reports, Images, and Microsoft® Excel® Spreadsheets
• Date and Time of each login session of End-User
• Failed Login Attempts and Events
• User Access Retrieval Sessions such as but not limited to “Forgot Password,” “ Change Password,” and “ First Time User Activation” procedures.

Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Site:

• First and last name;
• Email address;
• Company Name
• Location
• Department

This data may be collected using the following methods:

• Information as received via Caresoft Sales team for Customer onboarding
• Information as provided by the Customer buying the Site’s subscription
• Information is provided and updated by the End User by contacting Caresoft support
• Information as provided by the Customer to host the Site as a private instance.

How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.
The data we collect automatically is used for the following purposes:

• To analyze user behavior and to improve the system efficiency.
• To ensure the experience is seamless and comfortable
• To track and trace the use of the Site by End User as per subscription packages
• The help informing future product road map features of the Site
• To collect statistics anonymously for management reporting on user count, clicks, page views, utilization, and other data for internal management reviews

The data we collect when the user performs certain functions may be used for the following purposes:

• User technical support as needed
• Management Reporting
• Fraud and anomaly detection

Who We Share Personal Data With Employees
We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Other Disclosures
We will not sell or share your data with other third parties, except in the following cases:

• If the law requires it;
• If it is required for any legal proceeding;
• To prove or protect our legal rights
• To buyers or potential buyers of this company in the event that we seek to sell the company.

How Long We Store Personal Data

• The United States of America.

When we transfer user personal data, we will protect that data as described in this Privacy Policy and comply with applicable legal requirements for transferring personal data internationally.

If you are located in the United Kingdom or the European Union, we will only transfer your personal data if:

• The country your personal data is being transferred to has been deemed to have adequate data protection by the European Commission or, if you are in the United Kingdom, by the United Kingdom adequacy regulations; or
• We have implemented appropriate safeguards in respect of the transfer. For example, the recipient is a party to binding corporate rules, or we have entered into standard EU or United Kingdom data protection contractual clauses with the recipient.

Your Rights as a User Under the GDPR, you have the following rights:

• Right to be informed;
• Right of access;
• Right to rectification;
• Right to erasure;
• Right to restrict processing;
• Right to data portability;
• Right to object.

Children
We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data, their parent or guardian may contact our data protection officer.

How to Access, Modify, Delete, or Challenge the Data Collected If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data, and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our data protection officer here:

DPO Name: Iceberg Support Team
email ID: iceberg3support@caresoftglobal.com

Do Not Track Notice
Do Not Track ("DNT") is a privacy preference that you can set in certain web browsers. We do not track the users of our Site over time and across third-party websites and therefore do not respond to browser-initiated DNT signals.

Cookie Policy
A cookie is a small file stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

We use the following types of cookies on our Site:

• Functional cookies Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;
• Analytical cookies Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example, data on the content you access, how long you stay on our Site, etc.; and
• Third-Party Cookies Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:
  a. Monitor and analyze user behavior anonymously.

Modifications
This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy, we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner, you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner's Office in the UK.

Jurisdiction
The exclusive jurisdiction for all claims and conflicts shall be the Courts of England and Wales.

Contact Information

If you have any questions, concerns, or complaints, you can contact our data protection officer, DPO Name, at email ID: iceberg3support@caresoftglobal.com