Privacy Policy

It is SurgeMetrix.com’s policy to respect your privacy regarding any information we may collect from you or which you may provide to us, in the circumstances set out below. Accordingly, we have developed this privacy policy in order for you to understand how we collect, use, communicate, disclose, safeguard and otherwise make use of your personally identifiable information (“Personal Data”).

We will only collect and use your Personal Data where:

• We have lawful grounds to do so, including to comply with our legal obligations;

• We are performing a contract with you for our services; and

• We have legitimate interests in using your Personal Data, and your interests and fundamental rights do not override those interests.

For the purposes of the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”), we, SurgeMetrix, are the “data controller”. If you have any questions about this policy or about how we use your Personal Data, please contact us via our contact details at the end of this policy.

This policy is effective as of 01 March, 2019. We review our privacy practices on an ongoing basis, and as such we may change this privacy policy from time to time. Please check this page frequently to ensure you are familiar with its current content.

1. Personal Data we collect via our website https://surgemetrix.com (the “Website”) Personal Data that you provide to us
   We only collect Personal Data where you choose to interact with us on the Website in the following ways:

   Activity	Type of Personal Data Collected
   When you sign-up to: receive free content, including whitepapers, studies, videos and offers;	Email address First name Last name
   When you complete the contact or media enquiries form	Email address Name Any Personal Data which you provide to us in the free text box of the form

   Data that we collect automatically

   We automatically collect certain information when you visit our Website – such as the type of browser and operating system you are using, and the domain name of your Internet service provider. We do not link this information with any Personal Data.
   We may also collect data automatically through our use of cookies on the Website. Please see our cookie policy to find out about the types of cookies we set and why, and how you can adjust your settings to disable cookies.

1. Use of Personal Data

   We will only use your Personal Data when the law allows us to. Most commonly, we use your Personal Data to:

   • Process and manage your use of our website;
   • Respond to your questions, comments and requests;
   • Where you have opted-in to receive marketing from us, deliver communications that are relevant to your preferences/may be of interest to you;
   • Administer a contest, promotion, survey or other site feature;
   • Ask for ratings and reviews of services or products;
   • Improve our services and Website through analysis of information.

1. Sharing of your Personal Data

   We take your privacy seriously and will not share your Personal Data with others, except as permitted by applicable law or as set out below: We share Personal Data as necessary with third parties who provide services or functions on our behalf and who require the information to provide those specific services to us or you. These third parties may include social media advertising platforms such as Facebook and Google Adwords for the purpose of custom audience generation and the development of targeting criteria for other audiences. Please note that we have appropriate data privacy safeguards in place with third parties with whom we share Personal Data as described above and who are providing services or functions on our behalf. We do not sell your data to data brokers.

1. Keeping your Personal Data secure

   We have implemented security policies and technical measures to safeguard the Personal Data we collect. We maintain physical, electronic and procedural safeguards that comply with applicable law, including the GDPR, to safeguard Personal Data from accidental loss, destruction or damage and unauthorized access, use and disclosure.

1. Periods for use of your Personal Data

   We will use and store your Personal Data only for as long as necessary, bearing in mind the uses of your Personal Data as described in this privacy policy and otherwise as communicated to you. We review the Personal Data we hold at regular intervals and delete permanently or anonymise any Personal Data which is no longer necessary.

1. Third-party links

   Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.  

1. Do Not Track signals

   We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

1. Children

   When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control.
   The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. This Website and our services are aimed at adults, and we do not knowingly collect any Personal Data relating to children aged under 13 years old. If you are under the age of 13, please do not provide us with any of your Personal Data, including your email address.

1. Fair Information Practices

   The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information. In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur: We will notify you via email within 7 business days. We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

1. CAN SPAM Act

   The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to:

   • Send information, respond to inquiries, and/or other requests or questions
   • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred. To be in accordance with CANSPAM, we agree to the following:

• • Not use false or misleading subjects or email addresses.
  • Identify the message as an advertisement in some reasonable way.
  • Include the physical address of our business or site headquarters.
  • Monitor third-party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using the link at the bottom of each email. If at any time you would like to unsubscribe from receiving future emails, follow the instructions at the bottom of each email, or email us at [email protected] and we will promptly remove you from ALL correspondence.

1. Access to and control over your Personal Data

   You have legal rights under applicable law in relation to your Personal Data. You can ask the following questions, or take the following actions, at any time by contacting us via email [email protected] or via our postal address:

   • See what Personal Data we hold about you (if any), including why we are holding it and who it could be disclosed to;
   • Ask us to change/correct your Personal Data;
   • Ask us to delete your Personal Data;
   • Object to the processing of your Personal Data;
   • Ask us to restrict the processing of your Personal Data;
   • Withdraw any consents you have given us to the processing of your Personal Data; and
   • Express any concerns you have about third parties’ use of your Personal Data.

1. Change of purpose

   We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to have an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

1. Contact Us

   Email for Privacy Questions: [email protected].
   Postal Address: 4613 N University Drive, 125, Coral Springs, FL 33067, United States.