Effective: December 23, 2019
Scope of this Policy
Privacy Shield Framework
What personal information do we gather?
How do we collect your personal information?
How do we use your personal information?
Do we share your information with outside parties?
What about security?
Do we give you access to your information?
Using your personal information to contact you
How can you unsubscribe from our database?
Cookies and Other Tracking Technologies
Behavioral Targeting/ Re-Targeting
Social Media Widgets
General Data Protection Regulation (“GDPR”)
California Consumer Privacy Act (“CCPA”)
1. Scope of this Policy
2. Privacy Shield Framework
Guidewire Software participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Guidewire is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
Guidewire is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Guidewire complies with the Privacy Shield Principles for all onward transfers of personal data from EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Guidewire is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Guidewire may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
3. What personal information do we gather?
There are times when we may need information from you, which includes your Internet address so that we can track unique visits to our site for analytic purposes. Additionally, we may need your personal information such as your name, and your postal and email address in order to grant you access to protected and secured sites or provide you with the opportunity to register for an event, to fulfill your requests for information including white papers, download updates to our products, or participate in an online survey. In other instances, we may ask you to provide us with information such as your product interests so that we can send you only the information that is useful to you, including articles, product and service alerts, new product and service announcements and event invitations.
If you wish to apply for a job within the careers section of the site, we will collect personal information about you such as name, email address, and phone number. We will also ask you to provide us with a cover letter and a resume. We use this information to contact you regarding the position in which you expressed interest, to determine whether or not you are qualified for the position and to contact you regarding setting up an interview.
If you choose to let us know on who introduced you to an opportunity found our career page, we will ask you for your referral’s name and email address. We will automatically send your referral a one-time email indicating you have been referred. We may store this information for the sole purpose of sending this one-time email and/or for tracking the success of our referral program. You or your referral may contact us at firstname.lastname@example.org to request that we remove this information from our database.
4. How do we collect your personal information?
5. How do we use your personal information?
Information we collect is used to determine what is most effective about our web site, to help us identify ways to improve sites, to personalize the visit for you through the use of "persistent cookies" if you permit it, and to determine how we can tailor our web site to make it more effective. We may also use data for other purposes, which we would describe to you at the point we collect the information (for example, if you are invited to register for an event or request more information about one of our products). When you supply Guidewire Software with your personal information, we may use the information to learn more about you so that we can develop better products and services or use the information, sharing it with our business partners, to inform you about new products, services and offers that may be of interest to you.
We post customer testimonials/videos on our Web site which may contain personal information. We do obtain the customer’s consent via email prior to posting the testimonial or video to post their name along with it. To request removal of your personal information from our testimonials or videos, contact us email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
6. Do we share your information with outside parties?
Guidewire has contracted with a trusted third party provider to manage its online employment application process. Guidewire's third party provider has agreed to comply with all regulations designed to protect your privacy. It will only use candidate information to process Guidewire employment applications and not for its own purposes. It will not disclose any personally identifiable information to any third party. During the recruitment process, candidate information will be accessed internally only by those Guidewire employees who are directly involved in the recruitment process.
In certain situations, Guidewire may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
This Web site contains links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites.
We encourage you to be aware when you leave our site and to read the privacy policies of each and every Web site that collects personal information.
7. What about security?
The security of your personal information is important to Guidewire Software and we take appropriate steps to maintain security of your personal information. The open nature of the Internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended. While this is out of our control, we aim to apply appropriate levels of security at all times. We use industry standard technologies and maintain current security standards to ensure that your personal information is protected against unauthorized access, disclosure, inappropriate alteration, or misuse.
We manage our server environment appropriately and our firewall infrastructure is strictly adhered to. We routinely employ current technologies to ensure that the confidentiality and privacy of your information is not compromised.
To safeguard against unauthorized access to your accounts, you are required to "sign on" using a user ID and a password to certain secured areas of the www.guidewire.com web site. Both user ID and password are encrypted when sent over the Internet. If you are unable to provide the correct password, you will not be able to access these sections. Despite all of our efforts, the Internet is inherently unsecure and we cannot guarantee that information provided online will be secure at all times. Suffice it to say that the security of your personal information is important to us and we will use all reasonable means to keep it as safe as possible.
8. Do we give you access to your information?
Upon request Guidewire will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at firstname.lastname@example.org.
You are entitled to have access to your information and require it to be corrected or deleted if it is inaccurate. You can do this by contacting us via email@example.com or send us a mail through our mailing address below. We will respond to your access request within 30 days.
By entering your personal information in the Guidewire Careers website you accept that we may retain your information and it may be held by Guidewire or by any third party company that processes it on our behalf. We'll store all the information you submit as part of your application. And, in the course of the recruitment process, we might record further information about you. We collect and process sensitive personal data only so far as is necessary to ensure we comply with legal requirements, for example under the equality of opportunity laws. We will retain your information for a minimum of 6 months from your last update, unless otherwise required by law. If you are hired by Guidewire, the personal information you have submitted will be retained as part of your employment record. If you have any question on our handling of personal information, please contact the recruitment team by email at firstname.lastname@example.org.
9. Using your personal information to contact you
If you have asked to receive communications or provided contact information to download white papers or access other resources, then we will use your name and the email address you provided only to contact you regarding other communications that may be of interest to you.
10. How can you unsubscribe from our database?
You may change your subscription status at any time by visiting our subscription status page and entering your registered email address. If you registered under multiple addresses you will need to enter each address you wish to unsubscribe. An email will be sent to the address provided in order to ensure that the unsubscribe request is valid. If you are unable to access our subscription status page, you may send an email to email@example.com and we will notify you of your subscription status. Please be sure to send your request from the email address you wish to unsubscribe or clearly state in the email body the email address you wish to unsubscribe.
You may also opt-out from receiving newsletter or promotional communications by following the instructions included in each newsletter or communication.
If you supply us with your postal address on-line you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by calling us at 650.357.9100 or send a letter to Guidewire Software, 2850 South Delaware St., Suite 400, San Mateo, CA 94403. Please provide us with your exact name and address. We will be sure your name is removed from the list we share with other organizations.
Persons who supply us with their telephone numbers on-line may receive telephone contact from us with information regarding new products and services or upcoming events. If you do not wish to receive such telephone calls, please let us know by calling us at the number above or sending us e-mail at the above address.
11. Cookies and Other Tracking Technologies
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or click stream data to analyze trends in the aggregate and administer the site. We link this automatically collected data to other information we collect about you.
12. Behavioral Targeting/ Re-Targeting
We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
14. Social Media Widgets
15. General Data Protection Regulation (“GDPR”)
Guidewire is committed to complying with the General Data Protection Regulation. GDPR expands the privacy rights of individuals based in the European Economic Area (“EEA”), and places new obligations on all organizations that handle personal information of these individuals. This section provides helpful information on your rights as an individual based in the EEA, and how and why we use your personal information.
Your Rights Under GDPR
If you reside in the European Economic Area (“EEA”), you have the right as a data subject to exercise the following rights by contacting us via the email and postal address in Section 16 below:
Right of access – you can request access to your personal information and information about how we process it
Right to rectification – you can request to have your personal information corrected if it is inaccurate and/or outdated and to have incomplete personal information completed
Right to withdraw consent – you can withdraw consent at anytime if you have previously consented to a certain processing of your personal information (e.g., withdrawing consent previously given to send you marketing communications).
Right to erasure (also known as the Right to be Forgotten) – you can request to have your personal information erased, where applicable (e.g., if personal information is no longer necessary in relation to the purposes for which it was collected/processed).
Right to restriction of processing – you can restrict the processing of your personal information in certain situations (e.g., if the accuracy of your personal information is contested).
Right to data portability – you have the right to receive your personal information electronically in a standard format to transmit it to another controller, where applicable (e.g., if processing is based on your consent).
Right to object – you have the right to object to processing of your personal information
Rights regarding automated individual decision making, including profiling – you have the right to not be subject to a decision based solely on automated individual decision making, including profiling.
Right to lodge a complaint – you have the right to lodge a complaint with a data protection supervisory authority if you believe we are mishandling your personal information under the GDPR requirements.
Depending on your interaction with Guidewire, we may act as a Controller or as a Processor of your personal information. A Controller determines the purposes and means of the processing of personal information while a Processor processes personal information on behalf of the controller. If we receive your personal information from our customers, please contact our customer directly with your data subject access request. Since we act as a Processor for our customers, they are better equipped in assisting you with your request. We will reasonably support our customers in fulfilling your request.
Purpose of Using and Sharing Your Personal Information
Under GDPR, we can use and share your personal information only where we have a proper reason to do so. These reasons, known as legal basis, include:
Contract Performance/Fulfillment - your personal information is processed in order to fulfill a contractual agreement. For example, we may use your name and email address to setup a Guidewire account after your purchase of our product.
Consent – We can process your personal information if you provide us with consent to do so. For example, we will send you marketing communication after you provide us with your consent.
Legitimate Interests – Using your personal information for legitimate interests help Guidewire to streamline processes, improve products and services, and to provide an enjoyable user experience while protecting your personal information.
Legal Obligation – We will disclose your personal information if we are required to do so by law. This may include sharing your information for law enforcement purposes.
Protecting Data Subject and/or Others – We may disclose personal information if such disclosure is in your vital interest or others.
To help you understand how the use of your personal information and legal basis fits together, we’ve put together the below table.
What do we use your personal information for? To contact you to provide information you requested (e.g., submitting a form via our website)
What is our legal basis for processing your personal information? Consent, Legitimate Interest
If legitimate interest is listed as one of the legal basis, what is Guidewire’s legitimate interest in using your personal information? To inform you about new products, services and offers that may be of interest to you
What do we use your personal information for? To cooperate with law enforcement, investigate fraud, protect Guidewire’s rights, your safety, and safety of others
What is our legal basis for processing your personal information? Legal Obligation, Protecting Data Subject or Others, Legitimate Interest
If legitimate interest is listed as one of the legal basis, what is Guidewire’s legitimate interest in using your personal information? By using your personal information in this manner, we are continually improving and streamlining how we deal with fraud investigations, comply with applicable legal obligation, and respond to legal request.
What do we use your personal information for? To engage in website analytics
What is our legal basis for processing your personal information? Legitimate Interests
What do we use your personal information for? To send you marketing communications to inform you of the latest news and announcements from Guidewire and provide you with interest based online advertisements.
What is our legal basis for processing your personal information? Consent, Legitimate Interests
If legitimate interest is listed as one of the legal basis, what is Guidewire’s legitimate interest in using your personal information? With your consent, we may send you marketing communications and deliver updates about our products that you may be interested in. We also provide insights for our product teams with respect to developing products for you.
What do we use your personal information for? To contact you to undertake customer satisfaction surveys, invite you to provide product reviews or for market research
What is our legal basis for processing your personal information? Legitimate Interests
If legitimate interest is listed as one of the legal basis, what is Guidewire’s legitimate interest in using your personal information? We take customers’ feedback into consideration in product development and designs to build features that are customer-centric.
What do we use your personal information for? To evaluate your candidacy for employment with Guidewire and to improve recruiting efforts
What is our legal basis for processing your personal information? Consent, Legitimate Interests, Legal Obligation
If legitimate interest is listed as one of the legal basis, what is Guidewire’s legitimate interest in using your personal information? We use personal information to determine whether you are a successful candidate for a position at Guidewire and to improve our recruiting efforts to attract the right candidate pool.
What do we use your personal information for? To post customer testimonials/videos on our website
What is our legal basis for processing your personal information? Consent, Legitimate Interests
If legitimate interest is listed as one of the legal basis, what is Guidewire’s legitimate interest in using your personal information? With our customer consent, we may post testimonials and videos on our website about our products and services.
You have no obligation to provide us with your personal information on our website as a visitor. Our customers have certain obligations to supply us with personal information to use our services and products (e.g., providing us with email address to receive maintenance schedule for a specific service)
International Transfer of Personal Information Collected
Your personal information may be processed in countries outside of the EEA. Your personal information may be transferred to and stored by us in the United States and in other countries in which we operate. If your personal information is transferred outside the EEA, we will protect your data by ensuring the recipient has adequate levels of protection in place (e.g., executing Standard Contractual Clauses with the recipient).
16. California Consumer Privacy Act (“CCPA”)
If you are a California resident (“Consumer”), you can exercise certain rights under the CCPA. In addition to the details in this Policy, the CCPA requires us to provide you with the following information. In particular, our Web site may have collected the following categories of personal information from its Consumers within the last twelve (12) months:
Category A. Identifiers
Examples A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Category B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Category C. Protected classification characteristics under California or federal law.
Examples Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Category D. Commercial information.
Examples Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Category E. Biometric information
Examples Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Category F. Internet or other similar network activity.
Examples Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Category G. Geolocation data.
Examples Physical location or movements.
Category H. Sensory data.
Examples Audio, electronic, visual, thermal, olfactory, or similar information.
Category I. Professional or employment-related information.
Examples Current or past job history or performance evaluations.
Category J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Category K. Inferences drawn from other personal information.
Examples Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Please note we do not collect all the personal information listed as examples above. They are listed to provide you with more information on what each category includes.
Further, CCPA does not include:
Publicly available information from government records;
De-identified or aggregated consumer information;
Information excluded from the CCPA’s scope, such as: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from you. For example, when you provide us with information to request a white paper.
Directly and indirectly from activity on our Web site. For example, from submissions through our Web site or website usage details collected automatically via tracking technologies (e.g., cookies).
Sharing Personal Information
We may disclose your personal information to a third party service provider for a business purpose. When we disclose personal information for a business purpose, we enter into a contract with these service providers to ensure they keep personal information confidential and not use it for any purpose except for those stated in the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category I: Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. Depending on the capacity in which you provide your personal information to us, you may exercise your CCPA rights as outlined below:
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
For sales - the personal information categories that each category of recipient purchased; and
For disclosures for a business purpose - the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Emailing us at email@example.com
Sending us mail at the postal address in Section 16 (General)
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
If we are unable to verify your identity based on your request, we will reach out to you for additional information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Put simply, we value your trust in us. So, we want to maintain your privacy and work with you to ensure that this Web site and the information and services we provide to you are a valuable resource for you. For any more information about this Web site or your visit, please contact us at firstname.lastname@example.org. You can also contact us at the address below:
Guidewire Software, Inc.
Attn: Privacy Team
2850 South Delaware St., Suite 400
San Mateo, CA 94403 USA
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