Privacy Policy

1. About this policy

This Privacy Policy explains how ALLOut Security, operated by the Gate Software group, collects, uses, shares, retains and protects personal data relating to customers, prospective customers, partners, suppliers, website visitors and other business contacts.

The Gate company with which you or your organisation deals is generally responsible for personal data used to establish and manage that relationship. Gate Software Development Ltd also manages the Gate group’s central customer-relationship systems and may be responsible, alone or together with the relevant Gate company, for personal data held in those systems.

The relevant Gate companies are:

• Gate Software Development Ltd, Cyprus;
• Gate Software Ltd, United Kingdom; and
• Gate Software Inc, United States.

For simplicity, this policy refers to these companies collectively as “Gate”. You do not need to determine which Gate company is responsible before contacting us. Gate will ensure that your enquiry or request is handled by the appropriate company.

Email: complianceofficer@alloutsecurity.com

Postal address: Office 2A Innovation House, Molly Millars Close, Wokingham, Berkshire, RG41 2RX, United Kingdom, marked for the attention of the Compliance Officer.

Website: https://alloutsecurity.com/

2. Personal data we process

Gate operates in a business-to-business environment. We therefore process limited personal data relating mainly to representatives of customers, prospective customers, partners, suppliers and other organisations.

This may include:

• name, job title and employer;
• business email address, telephone number and address;
• publicly available professional-profile information;
• contractual, licensing, billing and account information;
• correspondence, enquiries and meeting records;
• webinar, event, training and marketing preferences;
• website, browser, IP address and cookie information; and
• other information provided to us in business communications.

We do not intentionally collect special-category personal data or criminal-conviction information as part of our ordinary business activities. Please do not provide such information unless it is necessary and has been specifically requested.

3. How we obtain personal data

We may obtain personal data:

• directly from you;
• from your employer or another organisation with which you are associated;
• through customer, partner or supplier relationships;
• through emails, telephone calls, meetings, events and webinars;
• through our website, portals and online resources;
• from professional networking platforms and publicly available business sources;
• from business partners and service providers; and
• from other Gate group companies.

Where personal data is obtained from another source, we use it only where the use is relevant, proportionate and permitted by applicable law.

4. How and why we use personal data

We may use personal data to:

• establish and manage customer, partner and supplier relationships;
• prepare and administer contracts, quotations and software licences;
• manage invoicing, payments and financial records;
• provide access to customer portals, learning materials and support resources;
• respond to enquiries and communicate about products and accounts;
• administer webinars, events and educational materials;
• send relevant business-to-business marketing communications;
• maintain and protect our systems, accounts and information;
• investigate security incidents or misuse;
• comply with legal, tax, accounting and regulatory requirements; and
• establish, exercise or defend legal claims.

Depending on the activity, we rely on:

• legitimate interests, including administering our business relationships, licensing software, supporting customers, protecting our systems and carrying out proportionate business-to-business marketing permitted by applicable law;
• legal obligations, including tax, accounting and regulatory requirements;
• contractual necessity, where you are personally party to a contract or have requested steps before entering into one; or
• consent, where we are required or choose to rely on consent, including for certain marketing activities and non-essential cookies.

Where we rely on legitimate interests, we consider whether the processing is necessary and whether our interests are outweighed by your rights and interests.

Where we request personal data, we will indicate if it is required by law or necessary to enter into or administer a contract. If required information is not provided, we may be unable to establish or manage the relevant relationship, provide access to our resources, process a transaction or respond fully to a request.

5. Marketing

We may send relevant information about Gate products, educational materials, webinars, events and industry developments where permitted by applicable data-protection and electronic-marketing laws. Depending on the circumstances, we may rely on legitimate interests or consent.

You may object to direct marketing at any time by:

• using the unsubscribe option in a marketing email; or
• contacting complianceofficer@alloutsecurity.com.

We will stop using your personal data for direct marketing. We may retain limited information on a suppression list to ensure that your preference continues to be respected.

An objection to marketing does not require us to delete records that must be retained for contractual, legal, tax, accounting or other legitimate purposes.

6. ALLOut product data

ALLOut software is installed and operated locally within each customer’s own JD Edwards environment. Gate does not provide a hosted ALLOut service.

As part of the standard licensed solution, Gate does not host customer production environments or routinely access, receive, transmit or store customer production data. Customers should not send production data to Gate unless specifically requested through an approved support process.

Gate may hold limited business-contact, contractual, licensing, billing and correspondence information required to administer customer relationships.

7. How we protect personal data

Gate uses appropriate organisational and technical measures designed to protect personal data against accidental or unlawful loss, disclosure, access, alteration or misuse. These include access controls based on role and business need, multi-factor authentication for corporate systems, device and platform security controls, confidentiality obligations and incident-management procedures.

Access is limited to authorised employees and contractors who require the information for legitimate business purposes.

We maintain procedures for responding to suspected personal-data breaches and will notify affected individuals or relevant regulators where required by law.

8. Sharing personal data

We may share personal data where necessary with:

• other Gate group companies;
• cloud, technology, website, email, webinar and communications providers;
• banks, payment providers and financial-service providers;
• accountants, auditors, lawyers, insurers and other professional advisers;
• business partners where necessary for an agreed relationship;
• regulators, courts, law-enforcement bodies or public authorities; and
• parties involved in a potential corporate transaction.

Service providers acting on our behalf are subject to applicable contractual, confidentiality, security and data-protection requirements.

Some recipients, such as professional advisers, regulators and other Gate companies, may process personal data under their own legal responsibilities.

Gate does not sell personal data or disclose it to unrelated third parties for their own marketing without permission or another lawful basis.

9. International transfers

Gate operates internationally, and some Gate companies and service providers are located outside the United Kingdom or European Economic Area.

Where personal data is transferred internationally, Gate uses an applicable lawful transfer mechanism, which may include:

• an adequacy decision;
• the European Commission’s Standard Contractual Clauses;
• the UK International Data Transfer Agreement;
• the UK Addendum to the Standard Contractual Clauses; or
• another lawful safeguard.

Additional safeguards may be applied where required.

Further information, including a copy or description of the applicable safeguards, may be requested from complianceofficer@alloutsecurity.com.

10. Retention

Gate retains personal data only for as long as reasonably necessary for the purpose for which it was collected and to meet applicable contractual, legal, tax, accounting and regulatory requirements.

Generally:

• customer, contract, licensing and account records are retained for the duration of the relationship and thereafter for the period reasonably required for contractual, legal, tax, accounting or claims purposes;
• invoices and financial records are retained for the legally required period;
• correspondence is retained while relevant to the relationship or matter concerned;
• marketing information is retained while there is an active or reasonably anticipated business relationship, subject to periodic review and any objection or withdrawal of consent;
• suppression records may be retained to respect marketing objections; and
• security or legal records may be retained where necessary to investigate incidents or protect legal rights.

When personal data is no longer required, it will be deleted, anonymised or securely disposed of as appropriate.

11. Your rights

Depending on the applicable law and circumstances, you may have the right to:

• request access to your personal data;
• request correction of inaccurate information;
• request deletion of personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• object at any time to direct marketing;
• request transfer of information where the right applies;
• withdraw consent where processing is based on consent; and
• complain to a data protection supervisory authority.

These rights are not absolute and may be subject to legal conditions or exemptions.

Requests may be sent to complianceofficer@alloutsecurity.com. We may request information reasonably necessary to verify your identity and locate the relevant records.

We will respond within the period required by applicable law.

12. Automated decision-making

Gate does not use personal data to make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.

13. Complaints

Please contact us first if you have concerns about how Gate handles personal data:

Email: complianceofficer@alloutsecurity.com

You may also complain to the relevant data protection supervisory authority.

In the United Kingdom, this is the Information Commissioner’s Office.

Where EU data-protection law applies, you may complain to the Office of the Commissioner for Personal Data Protection in Cyprus or to the supervisory authority in the EU country where you live, work or believe an infringement occurred.

14. Cookies

Our website may use cookies and similar technologies.

Further information about the cookies used, their purposes and available choices is provided in our Cookie Policy.

Where legally required, non-essential cookies are used only with consent.

15. Changes to this policy

Gate may update this Privacy Policy to reflect changes to its activities, systems or legal obligations.

The current version will be published with its effective or last-updated date. Where a material change significantly affects how personal data is used, Gate will take reasonable steps to bring it to the attention of affected individuals.