Sypher Cookie Consent Manager

Privacy Policy

Last updated: January 7, 2022

Overview

Sypher Solutions ("us", "we", or "our", “Sypher”) operates the Sypher Cookie Consent Manager (the "Service").

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We collect and use your data to provide and improve the Service in accordance with this policy.

Definitions

Personal Data: data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data: data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the time when the User consent was received).

Beneficiary: means any legal entity or affiliated entities, and/or any agency or network acting on their behalf, which ordered the Service.

Data Subject: any living individual who is the subject of Personal Data.

User; You; Your: the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

Consent record: the user consent received for the use of cookies, to comply with GDPR and other relevant Regulations.

GDPR: means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data.

Cookies: small pieces of data stored on a User’s device by the web browser while visiting a website.

Data Controller: means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processor (or Service Provider): means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Information Collection and Use

We collect several different types of information for various purposes to provide our Service to you.

Cookie Preferences Data
While using our Service, we will ask you to choose what cookies you accept.

Usage Data
We collect information about how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the time and date of your consent, the language of the cookie consent banner displayed on your browser, unique device identifiers and other diagnostic data.

Location Data
We do not use or store information about your location (“Location Data”).

Cookies Data

We use cookies to store your consent options and to provide the Service. The following cookies are used:

Cookie Purpose Expires
SYPHER_CNST Holds the user cookie consent options, in order to use only the accepted services. 30 to 365 days
XSRF-TOKEN Cookie that prevents malicious scripts from submitting forms without user knowledge. 2 hours
sypher_consent_service_session Internal cookie to identify a session instance for a user. 2 hours

Use of Data and Retention

Sypher uses the collected data for the following purposes:

Purpose Categories of Data Retention period
To provide support and maintain our Service to you Cookie Preferences and Usage Data The retention period configured for the Beneficiary’s Subscription (30 to 365 days)
To provide Beneficiary support Cookie Preferences and Usage Data The retention period configured for the Beneficiary’s Subscription (30 to 365 days) and another 12 months afterwards
To develop our Service, and detect, prevent and address technical issues Cookie Preferences and Usage Data The retention period configured for the Beneficiary’s Subscription (30 to 365 days) and another 12 months afterwards
To comply with legal obligations Cookie Preferences and Usage Data The retention period configured for the Beneficiary’s Subscription (30 to 365 days) and another 12 months afterwards
Statistics/service improvement purposes Cookie Preferences and Usage Data The retention period configured for the Beneficiary’s Subscription (30 to 365 days) and another 12 months afterwards. Anonymized or aggregated data might be kept for up to 10 years.

Transfer Of Data

Your information, including Usage Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Germany and choose to provide information to us, please note that we transfer the data, including Personal Data, to Germany and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Sypher will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Usage Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data

Disclosure for Law Enforcement
Under certain circumstances, Sypher may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements
Sypher may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Sypher
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security Of Data

The security of your data is important to us. No method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Sypher is ISO 27001:2013 certified. ISO/ IEC 27001:2013 is an internationally recognized security management standard that specifies security management best practices and comprehensive security controls, following a set of best practice guidance.

Your Rights

Sypher aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed about what Personal and Usage Data we hold about you and if you want it to be removed from our systems, please contact us.

You have the right:

  • To access and receive a copy of the Personal Data we hold about you
  • To rectify any Personal Data held about you that is inaccurate
  • To request the deletion of Personal Data held about you
  • You have the right to data portability for the information you provide to Sypher. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.

Please note that we may ask you to verify your identity before responding to such requests.

Service Providers

We employ third party companies to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We use third-party Service Providers to serve our traffic under the domains cdn.sypher.eu and consent.sypher.eu. This means these providers have access to your IP address and other information sent by your web browser. This information is used for security purposes. Neither we nor our providers track any individual user.

The list of service providers we’re using:

  • Amazon Web Services EMEA SARL – data center hosted in Germany. For more information on the privacy practices of Amazon, please visit the following web page: https://aws.amazon.com/privacy/

Children's Privacy

Our Service does not address anyone under the age of 13 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via a prominent notice on our Service, prior to the change becoming effective and update the "last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us.