Privacy Policy

Metra Vision (“we” or “us”) provide this policy to inform you of our personal information handling practices for personal information we collect from those who contact us by phone or email and visitors to our website www.metravision.com, and our web and mobile sites operated by us that link to this policy (“site” or “sites”).

This policy (together with our Terms of Use, Cookie Policy and any other documents referred to in it) sets out the basis on which any personal data, personally identifiable information, or personal information (“personal data”) we collect from you, or that you provide to us, through our sites will be processed by us. This policy does not cover any personal data we collect offline or that we process as a service provider for clients.

Local laws may provide for various data subject rights that provide individuals with the right to request access to their personal data, correction of their personal data that is in the possession or under the control of Metra Vision, and withdrawal of consent to process their personal data. This list is not exhaustive and may vary by local law and jurisdiction.

When you contact us, or make an inquiry, via our site, your data will be collected and controlled by Metra Vision who will share that data with our relevant affiliate company to which your inquiry, or request, relates. For example, if you inquire about engaging Metra Vision then your personal data may be shared with Metra Vision for these purposes. In such event if Metra Vision may be considered controllers of your data under applicable law (for example, the General Data Protection Regulation 2016/679 and its implementing national legislation and the UK GDPR (the “Privacy Legislation”)). We may also share your personal data with our other parties from time to time for the purposes set out in this privacy policy.

Unless we notify you otherwise.

Information we collect about you

We will collect and process the following data about you:

• Information you give to us. This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you request information about our services, and when you report a problem with our site.

  The information you give us may include your name, address, e-mail address and phone number, and other information that you choose to provide. Providing such personal data is voluntary. However, without providing such personal data, we will not be able to provide you with information or services you request from us. You will know what personal data you provide because you will actively submit it to us.

• Information we collect about you. In addition to the personal data that you actively provide, for us to monitor and maintain the performance of the sites and to analyze trends, usage and activities in connection with the sites, to measure the effectiveness of advertising we serve to you, and to deliver relevant advertising to you, the sites may automatically collect, process and store certain information from you, to the extent permitted and under the conditions set out under applicable law:

• Technical information, including the domain and host name from which you access the Internet, the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone and country setting, browser plug-in types and versions, operating system and platform; and

• Information about your site visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Information we receive from other sources. We are working closely with third parties (including, for example, marketing services and recruitment agencies) that may provide us with additional information about you.

If we are unable to collect this information, this may affect the provision of the services you have requested from us.

Cookies

To the extent permitted under applicable law, our site uses cookies and similar technologies to distinguish you from other users of our site and enable us and third parties to automatically collect information about how you access and use our sites, and about the device you use to access our sites. This helps us to provide you with a good experience when you browse our site and also allows us to customize and improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy. Some web browsers include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. You can make certain choices about cookies and similar technologies to communicate your choice not to be tracked online in our privacy preference center. But we may not respond to DNT signals. As no uniform technology standard for recognizing and implementing DNT signals has been finalized yet, we may not be able to respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

Uses made of the information

We use information held about you in the following ways:

• Information you give to us. To the extent permitted under applicable law, we will use this information:
  • To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
  • To provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about, when permitted by applicable law;
  • To provide you, or permit selected third parties to provide you (where you have consented to such sharing when required by applicable law), with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you, or where you have consented to this, or where we can otherwise lawfully do so.

• To notify you about changes to our service; and

• To ensure that content from our site is presented in the most effective manner for you and for your computer.

• Information we collect about you. To the extent permitted under applicable law, we will use this information:

• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• To improve our site to ensure that content is presented in the most effective manner for you and for your computer;

• As part of our efforts to keep our site safe and secure;

• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

• To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

• Information we receive from other sources.To the extent permitted under applicable law, we will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

• To the extent permitted under applicable data protection law, we may share your personal data with:
• Any member of our group, which means our subsidiaries.
• Selected third parties including:

• Service providers who act as our data processor who are subject to contractual obligations to implement technical and organizational security measures to safeguard the personal data and to process the personal data only as instructed. These third-party service providers assist us in assessing our information security controls, maintaining our site, analyzing our site traffic, and in providing services and information to us and to users of our site;

• Advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others. We may provide advertisers and advertising networks with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target;

• Analytics and search engine providers that assist us in the improvement and optimization of our site;

To the extent permitted by applicable data protection law, we will also disclose your personal data to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If we or our subsidiaries, or substantially all of the assets of any of the foregoing, is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or request of law enforcement, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of us or our subsidiaries, our employees, customers, or others.

Overseas Disclosures

Your personal data may be disclosed to employees, representatives, or other third parties operating outside of the country you are based who work for, or are engaged by us or our subsidiaries in other countries, including the USA and in other countries that we operate, and to our service providers who may be located outside of the country you are based, including the USA and in other countries that we operate. We note that these persons and third parties may also store, transfer or access personal data outside of the country you are based.

In disclosing your personal data overseas, we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal data in accordance with applicable laws. For any further information on the safeguards we adopt to ensure the protection of your personal data, you can contact us using the contact details indicated below.

Contacts and Complaints

We rely on personal data provided by you. In order to ensure that personal data provided to us is current, complete and accurate, please update us if there are any changes to the personal data provided to us.

Questions, comments or requests regarding this privacy policy are welcomed and should be addressed to the VP, Information Security and Governance at contact@metravision.com or by mail at Metra Vision, 70 West Madison Street, Chicago, Illinois 60602. Similarly, if you have any complaints about our privacy management practices, you can contact us at the same details. You may also have a right to raise your complaint with the relevant privacy regulator in your jurisdiction.

We may make changes to this notice, including material changes, from time to time. We will inform you of any changes to the processing activities described in this notice before we start that new processing.

EEA+ Supplemental Data Protection Law Disclosures

Metra Vision provides to residents of the European Economic Area, Switzerland and the United Kingdom (EEA+) the following disclosures to supplement the Website Privacy Policy.

Data Controller: The data controller is Metra Vision, a US corporation and based at 70 West Madison Street, Chicago, Illinois 60602.

Legal Bases for Processing under European Union and United Kingdom law: Legal bases for the processing of your personal data by Metra Vision are:

(i) performance of a contract, where we have entered into a contract with you and need to process your personal data to fulfil our contractual obligations to you (Art. 6 (1) lit. b GDPR/UK GDPR),

(ii) our legitimate interests (Art. 6 (1) lit. f GDPR/UK GDPR) for the transfer of your personal data within the group of companies which are the following: for internal administrative and support purposes,

(iii) compliance with a legal obligation to which Metra Vision is subject (Art. 6 (1) lit. c GDPR/UK GDPR), for example if we are required by law to disclose personal data to law enforcement agencies, or governmental authorities,

(iv) our legitimate interests for the purposes of exercising our legal rights or defending legal claims,

(v) our legitimate interests (Art. 6 (1) lit. b GDPR/UK GDPR) for the transfer of your personal data in connection with a transfer of all or part of our organization or assets which are the following: the orderly transition of all or part of our business,

(vi) our legitimate interests to protect and defend the rights or property of us or third parties, including enforcing agreements, policies and terms of use, and in an emergency including to protect the safety of our employees or any person which are the following: to protect the property, rights, and safety of any person and to prevent fraud. Information on the balancing test is available upon request,

(vii) your consent to the processing (art. 6 (1) lit. a GDPR/UK GDPR) for marketing and advertising purposes, as required by applicable laws.

Recipients in Third Countries: The personal data that we collect or receive about you may be transferred to and processed by recipients that are located inside or outside the EEA+ and which are not recognized from an EEA+ law perspective as providing for an adequate level of data protection. These third parties are generally cloud hosting and internet service providers, operating systems and platform providers, and certain technology partners. When interacting with our site or contacting Metra Vision, you transfer personal data to the United States. And Metra Vision may transfer your personal data to the UK, Australia, Japan, Canada, Germany, Switzerland, and Ireland. Transfers from Switzerland to the UK, Germany, Canada and Ireland do not require additional safeguards. Transfers from Switzerland to Australia, Japan, and the US are based on your consent. To the extent your personal data are transferred to countries that do not provide for an adequate level of data protection from an EU or UK law perspective, we will base the respective transfer on appropriate safeguards (Art. 46 GDPR/UK GDPR), such as standard data protection clauses adopted by the European Commission, and any supplementary measures as necessary in order to adequately protect your personal data. You can ask for a copy of such appropriate safeguards by contacting us as set out in the contact section.

Period of Data Storage: Your personal data will be retained for as long as necessary to provide you with the services requested, which in most cases does not exceed 5 years from the date of collection of the data. When Metra Vision no longer needs to use your personal data to comply with contractual obligations, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your information, including personal data, to comply with statutory retention periods e.g. for tax purposes for a legally prescribed time period thereafter, or if we need it to preserve evidence within statutes of limitation. With regard to personal data collected through cookies or similar technologies, details are provided in the Cookies Policy.

Data Subject RightsUnder applicable law, you may have the following rights in relation to your personal data. These may be limited under applicable data protection law.

(i) Right to request from us access to personal data: You have the right to confirm with us whether your personal information is processed, and if it is, to request access to that personal information including the categories of personal information processed, the purpose of the processing and the recipients or categories of recipients. You have the right to obtain a copy of the personal data undergoing processing. However, this is not an absolute right and the interests of other individuals may restrict your right of access.

(ii) Right to rectification: You have the right to obtain from us rectification of inaccurate or incomplete personal information concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

(iii) Right to erasure of your personal data (right to be forgotten): You have the right to ask us to erase personal data concerning you.

(iv) Right to restriction of processing: In limited circumstances, you have the right to request that we restrict processing of your personal data.

(v) Right to data portability: You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that personal data to another entity without hindrance from us.

(vi) Right to object: Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data.

Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.

(vii) Right to provide guidelines: For France specifically, you have the right to provide us with guidelines as to the processing of your personal data after your death, either directly or via a trusted third-party.

You also have the right to lodge a complaint with a supervisory authority and you can contact the authority when the exercise of your rights is subject to delay, restriction or exclusion by the data controller. If you have declared your consent for any personal data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. You can exercise your rights by contacting us as set out in the contact section.

Failure to Provide Personal Data: Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the services you have requested from us. In this case, we may have to cancel the provision of the relevant services to you, in which case we will notify you.