Effective Date: April 3, 2019
- WHAT PERSONAL INFORMATION DO WE COLLECT?
This is how we collect Personal Information from our customers, users, and visitors of our Site (together, “Individuals”):
- Account Creation. If you create an account by registering with the Services (“Account”), we’ll collect certain Personal Information about you, such as your name, email address, and phone number.
- Communications with Us. We may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.
- Data Collected Via Our Services. We will collect any and all information, data files, and Customer Data (including any of your or your customers’ Personal Information included in such data files or Customer Data), provided by you to the Services whether directly by transferring such files, or indirectly by granting Vintellus access to your third party accounts where such files are stored.
- Security Credentials Data. We collect user IDs, passwords, password hints, and similar security information required for authentication and access to our users’ accounts.
- Surveys. We may contact you to participate in surveys. If you decide to participate, we may ask you for certain information which may include Personal Information.
- Posting. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections. So please use discretion when posting anything on such platforms.
- Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
- (d) Location Information. When you use our App, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
- Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices. We also automatically collect some information regarding your use of the Services by placing cookies and other technologies on our Site. For more information on Cookies, please see Section 6.
- HOW DO WE USE YOUR INFORMATION?
We Process Personal Information about Individuals for a variety of business purposes, including:
- To Provide Services, and Other Information Requested including to:
- provide Services and communicate with you;
- manage your information and Accounts;
- respond to questions, comments, and other requests;
- provide access to certain areas, functionalities, and features of our Services;
- answer requests for customer or technical support, and troubleshoot problems;
- allow you to register for events.
- For Administrative Purposes including to:
- measure interest and engagement in our Site and Services;
- conduct research and development;
- create Aggregate Data (as defined in the Terms of Service) to enhance machine learning, improve our algorithm, and contribute to our artificial intelligence driven database;
- improve our products and Services;
- develop new products and Services;
- ensure internal quality control;
- verify Individual identity and for fraud prevention;
- communicate with you about your Account, activities on our Site and Services and policy changes;
- process your financial information and other payment methods for products or Services purchased (including through our third party payment processor);
- prevent potentially prohibited or illegal activities;
- enforce our Terms, and send you notices and alerts;
- network and information security;
- comply with the law;
- any other legitimate purpose.
- To Market Our Products and Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest to you, including:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- For direct marketing and research (including marketing research);
- Other purposes disclosed to you, or that you consent to, when you provide Personal Information.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as described below.
- De-identified and Aggregated Information Use. We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Site and Services, or other analyses we create. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, marketing, and any other legally permissible purposes.
- WITH WHOM DO WE SHARE YOUR INFORMATION?
We may share your information as follows:
- We Use Vendors and Service Providers. We may share your information with our vendors and service providers. For example, we may share your information with providers of IT, web hosting, and related services, or with our third party payment processors, and other service providers that help us with the provision of the Site and Services. With respect to onward transfers to agents under Privacy Shield, Privacy Shield requires that we remain liable should our agents Process Personal Information in a manner inconsistent with the Privacy Shield principles.
- Sharing Content with Friends or Colleagues. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend and/or colleague to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Vintellus or any other third parties for any other purpose.
- Your Manager, Colleagues You Choose, And Others Up the Corporate Chain. We will share information about the corporate account you are working on, and the names of the sales leads within that organization that you are following, with your manager and others that are upward managers within your organizational hierarchy. We also allow you to voluntarily share this information including without limitation, any notes, contact details and any other information you choose to share with your colleagues within your organization.
- Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Vintellus may allow third party advertising partners to set Technologies (as defined in Section 6) and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners for targeted advertising or interest-based advertising. You will be able to opt out of such sharing by following the instructions below.
- Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information and other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
- Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
- INFORMATION WE PROCESS ON BEHALF OF OUR CUSTOMERS (AS DATA PROCESSORS)
- Our customers may choose to use our Services to Process some of their Customer Data, which may contain Personal Information. The data that we Process through our Services for our customers is Processed by us purely as a data processor, on behalf of our customer, and in accordance with our customers’ instructions, and our privacy practices governing the Processing of such data will be in accordance with contracts that we may have in place with our customers.
- If you have any questions or concerns about how such data is handled or would like to exercise your rights as a data subject, you should contact the person or entity who has contracted with us to use the Services to Process your data (i.e., the data controller). Our customers control the Personal Information in these cases and determine the type of security settings and other details regarding their Account, including without limitation, how and for what purpose the data collected on their behalf should be Processed. We will, however, provide assistance to our customers to address any concerns you may have, in accordance with the terms of our contract with them. For a list of our sub-processors, contact us as described below.
- COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Analytics. We may also use various analytics service providers including, Google Analytics and Mixpanel to collect information regarding visitor behavior and visitor demographics on our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/.
- You can opt out of collection and Processing of data by these individual analytics services by accessing the following links: (i) for opting out of collection by Google, you can use the following link: http://tools.google.com/dlpage/gaoptout. (ii) for opting out of collection by Mixpanel: https://mixpanel.com/optout/. In addition, you can opt out of such collection by any of these services, by accessing a common link provided under Section 9 (Your Choices- Cookies and Interest-Based Advertising).
We use such Technologies for these purposes:
- Operationally Necessary. This includes Technologies that allow you access to our Site, App, Services, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as saved search, or similar functions;
- Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services, and so we can improve our Services;
- Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign into our Site or Services or keeping track of your specified preferences, interests, or past items viewed;
- Advertising or Targeting Related. We may use first party or third party Technologies to deliver content, including ads relevant to your interests, on our Site and Services or on Third Party sites.
- THIRD PARTY WEBSITES, SOCIAL MEDIA PLATFORMS AND SOFTWARE DEVELOPMENT KITS
The Services may contain links to other websites and other websites may reference or link to our Site or other Services. We do not control such third party websites or resources. So please read the privacy policies of each such website before you provide any information on it.
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
- INTERNATIONAL DATA TRANSFERS
All information Processed by us may be transferred, Processed, and stored anywhere in the world- the United States, India, or other countries. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Accordingly, Your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
In addition, Vintellus has agreed to cooperate with the panel established by local EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning Personal Information transferred from the EU and Switzerland. For more information or to submit a complaint to your local data protection authority, please visit https://edpb.europa.eu/about-edpb/board/members_en. Such independent dispute resolution mechanisms are available free of charge.
Under certain conditions, you may also have a right to invoke binding arbitration under Privacy Shield. For additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The FTC has jurisdiction over Vintellus’s compliance with the Privacy Shield.
- YOUR CHOICES
- General. You may opt out of certain uses of your Personal Information, or even withdraw your previously provided consent at any time and prevent further Processing by contacting us as described below. Please note, however, that the opt out does not apply to, and we may still collect and use, any non-Personal Information regarding your activities on our Site, Services and/or information from the advertisements on third party websites for other legal purposes as described above.
- “Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Sorry- we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. You may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs via the following links: www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
- RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another entity (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by Vintellus, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, Vintellus will take steps to verify your identity before fulfilling your request.
- DATA RETENTION
- SECURITY OF YOUR INFORMATION
We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we’ll attempt to notify you electronically by posting a notice on the Services, by mail or e-mail.
- CHILDREN’S INFORMATION
The Site and Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below, and we’ll promptly take steps to delete such information and terminate the child’s account.
- CALIFORNIA PRIVACY RIGHTS
- SUPERVISORY AUTHORITY
If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.
- CONTACT US
- “Personal Information” is any information relating to an identified or identifiable natural person.
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.