Complexity Intelligence LLC recognizes the value of your data and your privacy. For this reason, it is constantly committed to their protection and defense, always offering maximum security and confidentiality. 

In this regard, it adheres with satisfaction to the EU's data protection law, also known as GDPR (General Data Protection Regulation),  and undertakes to take all necessary measures to ensure the compliance of its platform and of its product / service portfolio with this regulation.

What is the GDPR ?

The GDPR, which stands for General Data Protection Regulation, is a European Regulation which will supersede the Data Protection Directive 95/46/EC and which will be applied from 25 May 2018.

What are its goals?

- strengthen the security and protection of personal data in the EU;
- harmonize data protection law across the EU;
- guarantee the same level of data protection and security either across all the EU Member States and across all third countries, outside the Union, where EU citizens' personal data are transferred, in order to allow their free and safe movement.

What is "Personal Data" ?

Personal Data refers to any information elating to an identified or identifiable natural person (Data Subject), providing details on his physical and psychological characteristics, on his political, religious opinions, preferences, hobbies, passions, on his relationships, on his economic and financial situation ...

Personal data can be classified into:

- Identification data: any data relating the natural person identification like name and surname, telephone number, date of birth, residential address, credit card number ... Although some of this data, taken individually (e.g. date of birth, address, name and surname),  does not uniquely allow the identification of the natural person, however, their combination can help achieve this goal. 

- Special categories of personal data: any sensitive data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation. ue to the particular nature of these data, their processing is allowed only with the explicit consent of the data subject, with the exception of the cases listed under Article 9.

- Judicial data: any data that may disclose that a natural person is the subject of judicial measures the law. Therefore, their processing must be under the control of the public authority.

Personal data processing principles

The processing of personal data must be based on the principles of lawfulness, fairness and transparency. 

- LAWFULNESS: the processing is lawful if the natural person has given his consent to the processing of his personal data for one or more purposes; if the processing is necessary for the performance of a contract; if the processing is necessary for compliance with a legal obligation; if the processing is necessary in order to protect the vital interests; if the processing is necessary for the performance of a task carried out in the public interest; if the processing is necessary for the purposes of the legitimate interests. (looking at Article 6 GDPR).

- FAIRNESS: in cases where explicit consent is required for data processing, the consent must be demonstrable, discernible if given for more purposes, freely given, revocable at any time.

- TRANSPARENCY: any information, communications and methods relating to the processing of personal data must be provided in a concise, accessible, unambiguous and easy to understand, using a plain and clear language.

Who are "Data Subject"," Data Controller" and "Data Processor" ?

- Data Subject : any living individual identified and identifiable through his / her personal data;

- Data Controller : natural person, legal entity (companies, associations ...), authority that determines the purposes for which and the manner in which any personal data are, or are to be, processed.

- Data Processor : natural person, legal entity (companies, associations ...), authority authorized by the Data Controller to process, on their behalf, the personal data of the data subject.

What are we doing to keep your data secure and safe ?

As an ICT company, Complexity Intelligence LLC, through its DataKnowl platform and through the development of new products / services,  manages your data with high security. DataKnowl platform is designed according to the highest safety standards, adopting all the technological tools and operating procedures to ensure maximum safety, according to the "by design and by default" philosophy. 

We have identified the following areas on which we will focus:

1. ACCESS CONTROL: access to the data is allowed only to staff or automated systems authorized and exclusively for work-related purposes. The persons authorized to access the data are bound by contract to the utmost secrecy and confidentiality.

2. DATA PROCESSING AND STORAGE: data are kept for a limited period of time strictly necessary for the purpose of the processing  and / or for the provision of the service, unless a longer time is established by legal obligations. The data are stored in data centers with the following certifications: ISO 27001, PCI DSS 3.2, ISO 27017, ISO 27018.

3. DATA DELETION: upon request, and if there are no legal obligations for the conservation, it is possible to proceed with the cancellation of the data according to the procedures established by the GDPR.

4. ENCRYPTION: the user access to DataKnowl platform through the secure protocol HTTPS. The data in transit between the user's browser and the servers are therefore encrypted. Complexity Intelligence LLC uses cryptographic hash functions to protect access data. In the event of a security breach, the original password can’t be recovered from our servers. We use the EU-US Privacy Shield Framework (EU-US Privacy Shield). We adhere to the principles of privacy protection, regarding the collection, use and storage of personal data transferred from the EU to the US.

5. AUDIT & LOG: Complexity Intelligence LLC uses logging solutions, monitoring and continuous auditing of all the components of the DataKnowl platform, in order to guarantee maximum safety and efficiency. Through these tools and operating procedures,  Complexity Intelligence LLC is able to detect anomalous activities, up to any unauthorized access to data ("data breach"). In this event, Complexity Intelligence LLC will promptly notify you according to the procedures and timings defined in the GDPR.

This document is the result of a free interpretation of the rules set out in the GDPR. The contents of this page do not constitute a legal opinion. Subsequent modifications and additions are not excluded.
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