Always Connected.

Privacy

Overview

Your privacy is important to us. KVH Industries, Inc. and its subsidiaries and affiliates (collectively “KVH,” “we,” “us” or “our”) is a global company and we process your personal data when you interact with us by visiting our website, purchasing our products or using our services. Every time we process your personal data we do so by fully respecting your privacy and your other rights and freedoms.

KVH is a manufacturer of solutions that provide global high-speed Internet, television, and voice services via satellite to mobile users at sea and on land as well as a leading provider of commercially licensed entertainment including news, sports, movies, and music to commercial and leisure customers in the maritime, hotel, and retail markets.

KVH is committed to protecting the privacy and security of your personal data (described below in Information We Collect).

This Privacy Policy explains how we treat personal data about you that we receive in connection with:

  • Our websites (individually and collectively, our “Website”), including this website kvh.com, kvhmobileworld.com, and myKVH.com; and
  • The services and products KVH makes available pursuant to agreements with subscribers, their service providers and authorized users (individually and collectively the “Services”).

Also, please bear in mind that this Privacy Policy complements the Terms of Use and Cookies Policy posted on our Website.  Use of our Website is conditioned upon your agreement to the Terms of Use, Cookies Policy and this Privacy Policy.

Information We Collect

By “personal data,” this means any information regarding an identified or identifiable individual. Depending on the context of your interactions with KVH, we collect and use different types of personal data. We may use personal data from potential candidates for employment as well as personal data from website visitors, prospective clients and/or providers using our services through our websites for registration of services or cookies analytics.

  • Information collected from you when you browse our website: Through certain technologies employed by our Website, we collect non-personally identifiable information about you. For more details about this type of data collection, please refer to the Cookies Policy posted on our Website.
  • Information collected when using our products or services: When we or our partners provide certain services, we may obtain your physical location data. For example, when using mini-VSAT or using myKVH.com, we collect data identifying the actual location of a physical address or connected device using information such as GPS data, geocodes, latitude and longitude information, and images of the various locations. We supplement this data with your disclosed information about your location (such as your ZIP or postal code) to provide you with content that may be of interest to you. If you provide information about other individuals authorized to use your subscriptions account, you represent you have permission from these individuals. KVH disclaims any legal duty to verify the accuracy or completeness of any personal data provided to KVH.
  • Information collected when you are invited to visit a customized Website: On occasions, we may invite you to visit customized Websites via an email containing a personalized URL, a notice on a registration page, or in response to you logging on to a certain portion of our Website. If you are invited to visit one of these customized Websites, you may find it customized with references to products and/or services that we believe may be of interest to you based on your previous interactions with KVH and on information you have provided to us. While you are visiting these customized Websites, we may collect tracking or other non-personally identifiable information about your visit to better tailor the site to your interests. This can also be collected through the use of cookies and web beacons. Please refer to the Cookies Policy. If you do not want your information to be collected in this way, do not accept the invitation to visit these customized Websites.

Children’s Information

We do not knowingly collect personal data on children under age 16 without the verifiable permission of a parent or guardian. The content of our Website and the products and services available are not intended for, or directed to, children under age 16. If you are under 16 years of age, then please do not use or access our Website or any of our other Websites at any time or in any manner.

How We Use the Information We Collect

The purposes for which we collect and use your personal data may vary depending on the type of relationship you have with us, such as if you apply for a position with our company, if you are one of our clients or service providers, or a user of one of our websites. KVH always collects and uses personal data according to the purpose limitation principle. The use of personal data for new purposes will be consistent and meet your privacy expectations. Otherwise we will request your authorization.

KVH may use the information we obtain for:

  • Recruitment: if you apply for a position with our company we will use your personal data to consider you for employment and to administer your account.
  • Communications and account management: establish or activate your accounts, provision of services and manage our communications with you including providing appropriate technical support.
  • Marketing and analytics: send newsletters, offers or programs that may be of interest to you, perform data analyses to determine usage patterns and the effectiveness of our sales, marketing and advertising.
  • Business development: operate, evaluate and improve our business, including the analysis and enhancement of our products, services, and Website, and developing new products and services.
  • Security: protect against, identify and prevent fraud and other criminal activity, claims and other liabilities.
  • Administrative management: perform accounting, auditing, billing, reconciliation and collection activities.
  • Compliance with laws: comply with applicable legal requirements and our policies.

We may also use the information we obtain about you in other ways which we provide specific notice or opt-out at the time of collection.

Legal Basis for Data Collection and Use

KVH only collects and uses personal data when there is a fair and legal basis for its collection and use, for instance, when the collection of personal data is necessary to enter into a contract, to meet our legitimate interests, to comply with legal obligations or when we have your consent.

The information we collect when we enter into a contract or business relationship with you, unless indicated otherwise, is mandatory to develop our contractual relationship and to comply with legal obligations. For instance, some tax laws, labor, anti-fraud or compliance laws require organizations to collect certain information that may vary depending on the local regulations. Without the required mandatory information, we would not be able to work with you or provide you our services.

Marketing activities are usually based on your consent or to an existing business relationship with us. However, you can opt-out of these communications anytime and free of charge.

When we use your personal data for our legitimate interests (e.g. security, business development, marketing, analytics), we always conduct a balancing test in order to ensure that data subject rights are not overridden.

Information We Share

At times, KVH engages third party contractors, service providers, and other vendors to help us accomplish our business objectives. There are other circumstances where we may disclose personal data where required by law or in response to lawful requests by public authorities or judicial bodies. California residents have the right to request information regarding the disclosure of their personal data.

In order to provide you services worldwide, we share your personal data to our KVH entities. We also share some personal data you provide to us with trusted companies we have hired to provide services to and for us, such as sending out our newsletters, fulfilling orders you submit, administering our promotion and marketing activities or collecting and processing information on our behalf. These companies – our vendors – are contractually bound to use personal data that we share with them only to perform the services we have hired them to provide. Among the vendors whose services we employ may be companies that provision services, activation of products, distribute products or help us deliver online advertisements such as banner ads. Other vendors may collect and use information you provide to us to help us better understand the offers, promotions, and types of advertising that are most appealing to our customers.

We will also share your personal data in the event that the business of KVH is transferred to another entity by way of merger, sale of the company’s assets, or otherwise.

In certain circumstances, KVH may be required to disclose your personal data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

We may also disclose personal data in the context of any transaction involving all or a portion of the business.

California Residents

California Residents – Disclosure to Third Parties
Under California Civil Code sections 1798.83-1798.84, also known as the “Shine the Light Law,” California residents who use our Website are entitled to request and receive once a year, free of charge, a notice from us describing what categories of personal data we share with third parties for their direct marketing purposes. As indicated above, such sharing only takes place with your consent. That notice will identify the categories of information shared, the third parties and affiliates with which it was shared, and their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the contact address below. In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least thirty days for a response.

California Residents – Do Not Track Notice
Except as described in the Cookies Policy, we do not track Website visitors over time and across third party websites to provide targeted advertising and therefore our Website does not respond to Do Not Track (“DNT”) signals. You may opt out of tracking as described in the Cookies Policy. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your web browser may allow you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. Third parties that have content embedded on KVH’s websites such as a social feature or a stock ticker may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific KVH website from a certain IP address. Third parties cannot collect any other personal data from KVH’s websites unless you provide it to them directly.

Retention Periods

KVH applies the storage limitation principle in order to retain personal data in our records only for the length of time required to fulfill the purpose for which the data was collected.

According to our retention policy, we only keep personal data in our records as long as they are necessary for the purposes they have been processed. KVH adheres to our retention policy to determine how long we retain data, including personal data. The retention periods are established considering our legitimate business purposes and according to local regulations such as tax, employment law and other commercial regulations.

Your Choices

We offer you certain choices about how we communicate with you and how we use information that is collected from you. If you reside or otherwise find yourself in the territory of the EEA, United Kingdom or Switzerland, we are committed to facilitate and exercise rights granted by applicable data protection law in a timely manner.

Your Choices: If you have any inquiries or to exercise your rights and choices listed below, write to [email protected] or contact us through our postal address or by telephone. Please be aware that to protect your security and privacy, KVH may take reasonable steps to verify your identity prior to making changes to your personal data. Modifying or deleting your personal data may affect our ability to provide services to you.

  • Opt In, Opt Out or Unsubscribe to marketing communications: When you provide information to us on our Website, we will give you the opportunity to opt-in to receiving promotional and marketing information from KVH and/or selected third parties. In addition, in each communication you will be provided with the option to opt-out by clicking on the unsubscribe link. You may also change your preferences and choose not to receive any marketing communications from us by emailing us at [email protected], and we will honor your request. Also, please note that you may continue to receive materials while we are updating our lists. Regarding our use of cookies and your choices, see our Cookies Policy.
  • Right to access your own personal data: You have the right to obtain confirmation of whether and how we process your personal data, as well as the right to obtain a copy of this data by contacting us by email at [email protected].
  • Erasure, correction, objection and other requests: You have the right to obtain erasure, and correction of your personal data, under certain conditions. You may also object at any time to the processing of your personal data, based on your specific situation. In this case, we will assess your request and provide a reply in a timely manner, according to our legal obligations. For all the processing operations that are based on your consent, you can withdraw it at any time and we will stop those processing operations. To exercise these rights, send an email to us at [email protected] with the words “UPDATE MY INFORMATION” in the subject line.
  • Privacy rights under the EEA regulation: In addition to the previous choices, if you reside or otherwise find yourself in the territory of the EU, KVH is committed to also facilitate the exercise of these other rights granted by EU data protection law in a timely manner:
    • Marketing Practices: KVH does not engage in any automated decision making using your personal data. However, we may use our marketing automation software to determine your level of interest in our products and services for further engagement. We combine information collected through the use of cookies on our websites, such as IP address, with other information you provide us through webforms, by email or during trade shows to determine your interests in our products, so we can provide you with more relevant information about our products when we send you email marketing communications. We ask your consent to conduct these activities and you have the right to withdraw it at any time by sending us an email to [email protected].

    • Right to portability:       you have the right to obtain a copy of your personal data in a structured or commonly used and machine-readable format where technically feasible where we collected your data based on a contract or your consent. To exercise this right, send an email to [email protected].

    • Right to lodge a complaint with a supervisory authority      : you have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of the alleged infringement, if you are not satisfied with our response.

Cross-Border Transfers

KVH is a global organization and provides global services. Sharing information cross border is essential so that you receive the same high-quality service wherever you are in the world. As a result, subject to applicable law, your personal data may be transferred to, accessed from and stored in servers and facilities located outside the country where you live as may be necessary for the purposes described in this Privacy Policy. Where we transfer store, and process your personal data outside of the EEA, we have implemented appropriate safeguards to provide adequate level of data protection. To protect your personal data when it is transferred to the United States we have self-certified under the EU-US Privacy Shield and under the Swiss-US Privacy Shield. We also use contractual protections for the transfer of personal data from the EU (including, for example, the European Commission’s standard contractual clauses), or an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country.

When you interact with our Website, purchase our products or use our services, then your personal data may be transferred to the United States. Please see the following section for more information about the Privacy Shield.

When we transfer your personal data outside the EEA, we will protect that information as described in this Privacy Policy and in accordance with applicable law. We use contractual protections for the transfer of personal data from the EEA (including, for example, the European Commission’s standard contractual clauses). We have self-certified under the EU-US Privacy Shield and under the Swiss-US Privacy Shield, and abide by the principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity, Access, and Enforcement with respect to the EEA/Swiss personal information that it receives while it is a participant of the Privacy Shield program. When you purchase any product or service, access the myKVH.com site or use any KVH services, you understand and agree that we may transfer your personal data globally to KVH entities, affiliates or subsidiaries, as well as third-party service providers and vendors.

Privacy Shield

KVH complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union and Switzerland to the United States. KVH has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield website located at https://www.privacyshield.gov/.

KVH processes all the personal data we receive in the United States from the EU, the EEA, and Switzerland in accordance with the following Privacy Shield Principles:

  • Notice: Through this Privacy Policy and when we collect your personal data we provide you with complete information about how we process your personal data and our commitment with the Privacy Shield Principles;
  • Choices and Access: We provide you with different Choices, including the possibility to opt out before disclosing your personal data to a third party or if we intend to use it for unrelated purposes and the right of access to your own personal data;
  • Accountability for Onward Transfers: When your personal data is transferred to another organization, we take appropriate steps to sign the necessary contractual agreements to protect your personal data;
  • Security: We maintain reasonable and appropriate Security measures to protect your personal data from loss, misuse and unauthorized access, disclosures, alteration or destruction;
  • Data Integrity and Purpose Limitation: We only process personal data necessary for the relevant purposes of the processing above;
  • Data Retention: We keep personal data for no longer than is necessary to fulfill the defined purposes for which the personal data is processed; and
  • Recourse, Enforcement, and Liability: We provide different mechanisms for assuring compliance with these Principles according to the section below Dispute resolution.

Your Rights:

  • Right of access: You have the right to access your own data that has been transferred to KVH under the Privacy Shield.
  • Right of correction: You can request the correction, or amendment of your personal data to keep the information accurate and up to date.
  • Right to delete: You have the right to delete your personal data when it is no longer needed and there is no other legal ground that justifies its retention.

Disclosures and sharing of data

In accordance with our policy regarding disclosure and sharing of data, your personal data will only be shared as appropriate with third parties that process information on behalf of, or with, KVH. KVH employs contractual provisions with third parties to safeguard your personal data in accordance with this Privacy Policy and applicable law. Under certain circumstances, KVH in the U.S. may remain liable for the acts of these third parties if they process personal data in a manner that is inconsistent with the Privacy Shield Principles or applicable data protection law. KVH may also remain liable under the Privacy Shield Principles if the company’s third-party processor onward transfer recipients process relevant personal data in a manner inconsistent with the Privacy Shield Principles, unless KVH proves that it is not responsible for the event giving rise to the damage.

Dispute resolution mechanisms

  •  Complaint handling mechanism: In compliance with the Privacy Shield Principles, KVH commits to resolve complaints about our collection or use of your personal data. EU and Swiss individuals with any inquiries or complaints about our Privacy Shield policy or our handling of your personal data under the Privacy Shield, should first contact us by writing to the following address and we will respond to your inquiry promptly:Attn. Felise Feingold
    Vice President, General Counsel and Compliance Officer
    [email protected]
    KVH Industries, Inc.
    50 Enterprise Center
    Middletown, RI 02842 USA
  • Recourse to Arbitration: KVH has further committed to refer unresolved Privacy Shield complaints to American Arbitration Association, an alternative dispute resolution provider located in the United States. If, after attempting to address privacy questions or concerns with KVH, you do not receive timely acknowledgment of your complaint from us, or if you still have a specific privacy concern that has not been resolved to your satisfaction, please visit https://go.adr.org/privacyshield.html for more information or to file a complaint. The services of the American Arbitration Association are provided at no cost to you and you can submit your unresolved privacy concern to the following address:Submit your unresolved privacy concern to the American Arbitration Association for resolution:American Arbitration Association
    Case Filing Services
    877.495.4185: Toll free
    877.304.8457: Fax
    [email protected]
    https://go.adr.org/privacyshield.html
  • Contact your Data Protection Authority: If you are based in the EU or the EEA, you may choose to contact your local Data Protection Authority (“DPA”), or the Swiss Federal Data Protection and Information Commissioner, if you are based in Switzerland. Your DPA or the Swiss Commissioner may refer your complaint directly to the Department of Commerce on your behalf. In this case, the Privacy Shield Team will then work to resolve your concern.
  • US Department of Commerce’s Privacy Shield Framework: You may also have the option to select binding arbitration for the resolution of your complaint under certain circumstances. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework.

Enforcement and compliance

For purposes of enforcing compliance with the Privacy Shield, KVH is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield and to view KVH’s certification page, please visit the website of the US Federal Trade Commission on Privacy Shield.

If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

Security

KVH is committed to the security, confidentiality and integrity principle. We are committed to processing your data in a secure manner and have put in place commercially reasonable security measures to prevent the personal data we hold from being accidentally or deliberately compromised.

KVH uses industry standard administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. KVH’s Websites kvh.com and kvhmobileworld.com are SSL certified websites. SSL certificates are small data files that digitally bind an encryption key to a particular organization. KVH’s SSL certificates allow a secure connection from a web server to our browser.

We also conduct information risk assessments. We ensure that our staff understands the importance of protecting personal data, and we are responsibly managing access rights within the company. We include both physical security and IT security in our overall data security approach. We are diligent in selecting vendors that process personal data on our behalf so that they also ensure appropriate technical and organizational measures to protect the data.

KVH makes reasonable efforts to notify individuals and regulatory authorities, as required by law, if we reasonably believe that personal data has been stolen, disclosed, altered or infringed by an unauthorized person. We create and maintain a breach notification and reporting protocol.

We also endorse the concept of privacy by design which is an approach to projects that promotes privacy and data protection compliance from the outset. This means considering the privacy and security implications for any new project or process throughout its lifecycle.

Despite these security measures, you should be aware that it is impossible to guarantee absolute security with respect to information sent through the Internet.

Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy and related business practices at any time. We will duly inform you of any changes.

This Privacy Policy is subject to change from time to time. KVH will endeavor to post a notice of any changes to this Privacy Policy for a period of thirty (30) days following any such modifications. The time stamp you see on the policy will indicate the last date it was revised.

Severability clause

If any term of this Agreement is to any extent invalid, illegal, or incapable of being enforced, such term shall be excluded; all other terms hereof shall remain in full force and effect

If any term or provision of this Privacy Policy shall be found to be invalid, illegal or otherwise unenforceable, such finding shall not affect the other terms or provisions of this Privacy Policy, or the whole of this Privacy Policy, but such term or provision shall be deemed modified to the extent necessary to render such term or provision enforceable, and the rights and obligations of you and KVH shall be construed and enforced accordingly, preserving to the fullest permissible extent the intent and agreements set forth in this Privacy Policy.

How to Contact Us

At KVH we are committed to apply this privacy policy. For this reason, if you have any privacy concern or questions about how your personal data is used, please feel free to contact us at [email protected], through our postal address or by telephone.

You may also contact us at:

Felise Feingold
Sr. Vice President, General Counsel & Compliance Officer
KVH Industries, Inc.
50 Enterprise Center
Middletown, RI 02842 USA
401-847-3327

If you are located in Europe, you may contact us at:

Felise Feingold
Sr. Vice President, General Counsel & Compliance Officer
KVH Industries A/S
Birkeroed Kongevej 150B
3460 Birkeroed, Denmark
+1 401-847-3327

Effective Date:  September 22, 2022

Always Connected.

We are a global leader in mobile connectivity, content, and value-added services with innovative technology designed to enable a mobile world and keep mariners always connected.

KVH Industries, Inc.
World Headquarters

50 Enterprise Center
Middletown, RI 02842
U.S.A.

Tel: +1.401.847.3327

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