Contrarian Technology, LLC and its subsidiaries and affiliates (collectively, “contek” or “we”) respect the privacy of Personal Data and are committed to protecting Personal Data. This Data Protection and Privacy Policy (this “Policy”) describes the policies and procedures Contek has implemented to protect Personal Data Processed by Contek in accordance with applicable Data Protection Laws. This Policy also describes how Contek collects, uses, and discloses Personal Data from your interactions with us, including when you visit Contek websites and other online platforms as well as your privacy rights. This Policy does not apply to the Personal Data of Contek’s employees, contractors, or job applicants, which are subject to separate data protection policies. Contek has voluntarily opted to apply the protections and obligations outlined in this Policy to all Data Subjects. However, such protections and obligations may be beyond the legal requirements of the jurisdiction of certain Data Subjects. Data Protection Laws vary widely across jurisdictions and while Contek will strive to meet this Policy for all Data Subjects, the Data Protection Laws for the Data Subject ultimately govern the protections conferred in the specific jurisdiction applicable to that Data Subject. Additionally, there may be certain rights applicable to you for which we may provide separate notice informing you of your rights and how to adequately exercise them.
Contek may collect your Personal Data on our websites. The technologies we use to track your movements around our websites may include cookies, tracking scripts and pixels, or tagging technologies, which we may employ to understand your preferences, improve your experience on our websites, etc. Most internet browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your end device or a message always appears when you receive a new cookie. Further information can be found on http://www.aboutcookies.org. Please note that disabling cookies may prevent you from using all the features of our websites.
We use tracking tools, such as Google Analytics, which generate information about your use of our websites. Such information may include a navigation path that you follow on our websites; how long you spend on our websites and subpages; the subpage from which you leave our websites; the country, region, or city from where you access our websites; returning or new visitor; and host name of the accessing computer (IP address). This information is transmitted to Google servers in the USA and stored there. Such information is used to evaluate the use of our websites, compile reports on Website activities, and provide other services associated with Website and internet use. Google may transfer such information to third parties where required to do so by law, or where such third parties Process the information on Google’s behalf. For additional information, see Google’s Privacy Policy at https://policies.google.com/privacy?gl=US&hl=en.
Contek limits the Personal Data it collects to what is necessary. Contek will only use Personal Data when Data Protection Laws allow Contek to do so. Personal Data shall be Processed in a manner that is adequate, relevant, and not excessive in relation to the intended business purpose(s) of such Processing. Depending on the nature of Contek’s interactions with you, we may Process your Personal Data for some or all of the following purposes: To respond to your questions and requests; To provide you with access to certain areas and features of our websites; For record keeping purposes; Data Subject giving consent to the Processing of his or her Personal Data for a specific purpose(s); Processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract; Processing is necessary for compliance with a legal obligation to which Contek is subject; Processing is necessary to protect the vital interests of the Data Subject or of another natural person; Processing is necessary for the purposes of the legitimate interests pursued by Contek or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal Data; For security and safety purposes, such as protecting against cyber threats; detecting, investigating, or preventing fraud and other illegal activities; and responding to legal and regulatory compliance obligations; and/or For other lawful purposes disclosed at the time we collect your Personal Data or otherwise with your consent. Contek does not use automated decision-making in Processing Personal Data in a way that will have a significant impact on you.
Contek has executed appropriate documentation designed to protect the privacy and fundamental rights and freedoms of Data Subjects and has taken appropriate measures designed to ensure data protection during the sharing of Personal Data.
Contek does not sell Personal Data to any third parties. Contek may share Personal Data with third parties such as service providers, software applications, or agencies to Process (maintain, store, use) on Contek’s behalf for recruiting and other business purposes. Contek requires all such Processors to take appropriate security measures to protect Personal Data in accordance with Contek’s policies and to maintain adequate documentation. Contek does not allow Processors to Process Personal Data for their own purposes and only permits them to Process Personal Data for specified purposes and in accordance with Contek's instructions. Please email inquiries@contek.io for a current list of third parties Processing Personal Data. Contek may share Personal Data with third parties to Process on their own behalf. Such third parties will be considered joint-Controllers of such Personal Data. While joint-Controllers have shared discretion over the purposes of Processing, all such Controllers agree to Process such shared Personal Data in accordance with Data Protection Laws and shall restrict Processing to the intended business purpose.
Contek may also share Personal Data about you if doing so is required or permitted by applicable law, including (i) to comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) to protect the safety, rights, and property of Contek or other persons; (iii) to enforce Contek’s policies and contracts; (iv) to collect amounts owed to Contek; or (v) when disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity.
Contek is a global company and may transfer Personal Data to Contek entities, affiliates, and service providers located in such jurisdictions as the United States, United Kingdom, European Union, Singapore, or other jurisdictions. Not all jurisdictions provide the same level of protection as your country of residence may provide. However, Contek shall not transfer Personal Data to a country or territory outside the jurisdiction in which it was Processed, except in accordance with the requirements prescribed under Data Protection Laws. Contek may transfer or provide access to Personal Data across jurisdictions and entities in accordance with its Data Protection Agreements and Intercompany Agreements, which are aligned with Data Protection Laws. Regarding transfers from the European Economic Area or the United Kingdom, Contek has taken steps to provide an adequate level of protection for Personal Data in accordance with Data Protection Laws.
Depending on the applicable data protection and privacy laws and regulations where you are located, you may be entitled to exercise some or all of the below Data Subject rights, as described herein. In accordance with Data Protection Laws and in certain circumstances, a Data Subject may possess the right to:
Request access to his or her Personal Data that Contek holds to check that it is accurately and lawfully being Processed. Specifically, in some jurisdictions you may request confirmation that we Process your Personal Data and ask for: (i) a portable copy of the specific pieces of your Personal Data; (ii) a list of categories of Personal Data (and Sensitive Personal Data) we have Processed about you; (iii) a list of categories of sources from which such Personal Data was Processed; (iv) a list of categories of Personal Data that we Processed or disclosed about you; (v) a list of categories of third parties to whom the Personal Information was disclosed; (vi) the business purpose for Processing your Personal Data; and/or (vii) details about the logic involved in any automated decision-making processes used (if applicable), as well as a description of the likely outcome of the process with respect to you.
Request correction of his or her Personal Data that Contek holds. This enables Data Subjects to have any incomplete or inaccurate Personal Data be corrected, though Contek may need to verify the accuracy of any new Personal Data provided. Request erasure (deletion) of his or her Personal Data. This enables Data Subjects to ask Contek to delete or remove Personal Data where there is no legitimate purpose for the Processing of such Personal Data by Contek. Contek may not always be able to comply with the request of erasure for specific legal reasons or other legitimate grounds, which will be notified to Data Subjects, if applicable, at the time of the request.
Object to Processing of his or her Personal Data where Contek is relying on a legitimate interest (or those of a third party) and he or she would like to object to the Processing because it impacts his or her fundamental rights and freedoms. Request restriction of Processing of his or her Personal Data. This enables Data Subjects to ask Contek to suspend Processing Personal Data in the following scenarios: (a) establishing the accuracy of Personal Data; (b) where Contek's use of Personal Data is unlawful, but there is no request of erasure; (c) where a Data Subject needs Contek to hold Personal Data even if retention is no longer required and it is needed to establish, exercise, or defend a legal claim; or (d) a Data Subject objects to Contek's use of Personal Data, but Contek needs to verify whether there are overriding legitimate grounds to use it.
To make a request, please send an email to inquries@contek.io. Contek shall accept and respond to, when applicable, any requests through the appropriate channels from an eligible Data Subject to exercise his or her rights and freedoms pursuant to Data Protection Laws. Contek shall use reasonable means to verify the identity of the requester, based on the nature and sensitivity of the request. You may designate an agent to submit requests on your behalf using the same methods described herein. When submitting a request, the agent must identify itself as your authorized agent.
If a Data Subject exercises any of the above privacy rights, Contek will continue to treat the Data Subject fairly and without discrimination.
You will not generally have to pay a fee to access your Personal Data or to exercise any of the above rights. However, Contek may charge a reasonable fee if the request is clearly unfounded or excessive. Contek will try to respond to all legitimate requests within thirty (30) days. Occasionally, it may take Contek longer if the request is particularly complex. Alternatively, Contek may refuse to comply with the request in certain circumstances.
Contek hopes that it will be able to address any Data Subjects concerns regarding the Processing of Personal Data. However, if you have any unresolved concerns, you have the right to complain to the data protection authority in your jurisdiction.