Effective Date: [June 18th, 2020]
- Information We Collect
- User Content
- How We Use Your Information
- How We Disclose Your Information
- How We Disclose Your Personal Data
- Data Retention and Correctness
- Cookies and Other Tracking Mechanisms
- Third-Party Analytics
- Do Not Track Disclosure
- Third-Party Links
- How to Access and Control Your Personal Data
- Your Choices
- Contact Us
Information We Collect
We collect information about you directly from you, from third parties, and automatically through your use of our Services. We may combine information collected from or about you from these various sources. You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature. The data we collect depends on the context of your interactions with EOSDA, the choices you make, including your privacy settings, and the products and features you use.
Information We Collect Directly from You. We collect information about you directly from you. For example, if you create an account with us, we will collect your name, email address, and password. If you pay for our Services, we will collect information necessary to process your payment, such as credit card information and billing address. We will also collect any other information that you provide to us through our Services, such as your email address if you sign up to get updates from us or your company name and country if you provide us with optional profile information.
Information We Collect About You from Third Parties. We also collect information about you from third parties. For example, if you log into our Services using a third-party platform (e.g., Facebook, Google, or LinkedIn), then we may collect the following information:
- Facebook. If you log into our Services using Facebook, you must enter your Facebook email address and password. We will ask that you grant us permission to access and collect your email address, name, and profile picture. If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public on Facebook.
- Google. If you log into our Services using Google, you must enter your Google email address and password. By logging in through Google, you are granting us access to your email address, name, and profile picture.
- LinkedIn. If you log into our Services using LinkedIn, you must enter your LinkedIn email address and password. By logging in through LinkedIn, you are granting us access to your email address, name, and profile picture.
Information We Collect Automatically Through Our Services. We automatically collect information about you through your use of our Services, including, without limitation:
- Log information, such as your Internet protocol (IP) address, the type of browser you are using, information about the device you are using, domain name, the website that led you to our Services, the website to which you go after leaving our Services, your location, and the dates and times you access our Services.
- Usage information, such as numbers of the scenes viewed by user, the combination of bands selected or used by user, and the types of analytics or algorithms a user applies.
Please see our Cookies and Other Tracking Mechanisms section below for more information. We may combine information we collect automatically with information we collect directly from or from third parties.
How We Use Your Information
We may use your information, including personal information and User Content, for the following purposes:
- Providing and Improving Our Services. To provide and maintain our Services; to improve our Services; to develop new features, products, or services; to authenticate users; to perform technical operations, such as updating software; to validate our users and ensure their qualifications to use our Services; and for other customer service and support purposes.
- Marketing and Communications. To communicate with you about your account and use of our Services, including to send you product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. Our communications with you may include communications via email. Please see our section regarding Your Choices for more information about how to change your communications preferences.
- Research and Analytics. To analyze how you interact with our Services; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.
- Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
In carrying out these purposes, we combine data we collect to give you a more personalized experience. However, to enhance privacy, we have built in technological and procedural safeguards designed to prevent certain data combinations. For example, we store data we collect from you when you are unauthenticated (not signed in) separately from any account information that directly identifies you, such as your name, email address or phone number.
How We Disclose Your Information
We may disclose your information, including personal information and User Content, as described to you at the time of collection or disclosure or as follows:
- Service Providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf. For example, we may disclose your information to third-party service providers to process payments on our behalf.
- Business Transfers. We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
- Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
- Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.
How We Disclose Your Personal Data
We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. When you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.
In addition, we share personal data among EOSDA-controlled affiliates and subsidiaries. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we've hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.
Finally, we will access, transfer, disclose, and preserve personal data, when we have a good faith belief that doing so is necessary to:
- comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
- protect our customers, for example to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone;
- operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks;
- Please note that some of our products include links to products of third parties whose privacy practices differ from EOSDA's. If you provide personal data to any of those products, your data is governed by their privacy statements.
Data Retention and Correctness
Irrespective of the above, EOSDA may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce EOSDA user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.
Cookies and Other Tracking Mechanisms
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process or to allow us to track your activities while using our Services. There are two types of cookies: session and persistent cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Services. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising both on our Services and on third-party services.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Services who disable cookies will be able to browse certain areas of the Services, but some features may not function (e.g., you may not be able to stay logged into your account).
Do Not Track Disclosure
Our Services do not respond to Do Not Track signals. For more information about Do Not Track signals, please click here. You may, however, disable certain tracking as discussed in the Cookies and Other Tracking Mechanisms section above (e.g., by disabling cookies).
How to Access and Control Your Personal Data
You can view, edit, or delete your personal data online for many EOSDA products. You can also make choices about EOSDA's collection and use of your data. How you can access or control your personal data will depend on which products you use. You can always contact EOSDA by email@example.com. We will respond to requests to access or delete your personal data within thirty (30) calendar days.
We have taken steps to help protect the personal information we collect. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Opting out of Marketing Emails. We may send periodic promotional emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
Our Services are not targeted to children under thirteen (13) years of age and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.
FOR EU & SWISS:
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, EOSDA is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
EOSDA’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, EOSDA remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless EOSDA proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, EOSDA commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact EOSDA by email at firstname.lastname@example.org.
EOSDA has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.