Privacy Policy

Updated: 21 April 2020

Table of Contents

  1. INFORMATION WE COLLECT

1.1. PRIVACY PRACTICES SPECIFIC TO PERSONAL INFORMATION

1.2. PRIVACY PRACTICES SPECIFIC TO TECHNICAL INFORMATION

1.3. INFORMATION COLLECTED BY THIRD PARTIES

  1. COOKIE POLICY

2.1. COOKIE & AUTOMATED DATA COLLECTION DEFINITIONS

2.2. WHY WE USE COOKIES AND AUTOMATED DATA COLLECTION

2.3. WHEN DO WE REQUIRE YOUR CONSENT

2.4. HOW TO MANAGE YOUR COOKIES

2.5. ONLINE TRACKING THROUGH THE PERSADO API

  1. SECURITY & RETENTION
  2. YOUR RIGHTS
  3. CHILDREN
  4. CHANGES TO THIS PRIVACY POLICY
  5. THIRD PARTY LINKS AND PRODUCTS
  6. EU – U.S. PRIVACY SHIELD
  7. ENFORCEMENT
  8. HOW TO CONTACT US
  9. DEFINITIONS

Persado created this Privacy and Data Protection Policy (“Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy explains the conditions under which and the purposes for which we collect and use your Personal Data.

We collect this Personal Data through:

Under applicable law Persado is considered a “Controller” of this data.

  • our “Services” :
    • our client portal;
    • services we offer, including but not limited to: Persado Enterprise, Persado Predict, Persado Pro and Persado Connect;
    • Persado API.

Under applicable law Persado is considered a “Processor” of this data, and our customer (or our customer’s customer) is the “Controller” of the data.

And in connection with:

  • the third parties to whom we disclose your Personal Data;
  • the choices and means, if any, we offer you for limiting the use and disclosure of your Personal Data.

We will not use or share your Personal Data except as described in this Privacy Policy.

  1. INFORMATION WE COLLECT

We may collect Personal Data about you when you use our Site or our Services.

We may collect different types of Personal Data:

Personal Information” and “Technical Information”.

  • Personal Information is information such as your name, email address and telephone number.
  • Technical Information is usage data and other technical information about how you use our Site and our Services.

 

1.1. PRIVACY PRACTICES SPECIFIC TO PERSONAL INFORMATION

  1. COLLECTION AND TYPES OF PERSONAL INFORMATION

This information may include:

  • Personal Information, such as your name, telephone number, company name (if applicable) and email address, that you will be asked to provide to us when you sign up or create an account to use our Services;
  • your credit card information, if you choose to pay us via credit card. Persado’s third-party contractor will collect and process this data subject to its policies and practices. Please see Section 1.3 (A) for more information about our third-party credit card processor’s policies and practices;
  • your name, email address and any other Personal Information you choose to include, or will be asked to provide if you choose to contact us via our Site;
  • information from or on behalf of our customers, used to provide our Services, subject to our contractual agreements (customer lists, MSISDNs, email addresses, etc.).
  1. USE OF PERSONAL INFORMATION

We may use your Personal Information for the following legitimate business purposes:

  • to respond to your requests and to provide you with access to the Site and our Services;
  • to respond to your inquiries, provide customer support services, and contact you about changes to the Site or our Services;
  • for billing and collection purposes;
  • to improve the Site and our Services;
  • for any other purposes disclosed at the time the information is collected or to which you consent;
  • to comply with our legal and regulatory obligations;
  • for business monitoring and internal record keeping, including maintain our accounts, complying with good practice and for other administrative, operational and security reasons;
  • as otherwise specifically described in this Privacy Policy;
  • for Marketing Purposes:
    • on the basis that the processing is necessary for the performance of a contract with you, or we are acting in our legitimate interests in the promotion and efficient running of our business.
    • to provide you with email notifications and other communications by email and telephone, on the basis that such use is necessary for the purposes of the legitimate interests pursued by us. For further information on this, see Section 1.1 (C) below.
  1. HOW WE SHARE YOUR PERSONAL INFORMATION

We will share Personal Information in the following circumstances:

  • To provide our Services
  • Surveys. From time to time, we may ask you to participate in surveys for our general business and marketing purposes. Any Personal Information provided to us in connection with a survey will be used only in relation to that survey, and any results from such survey will be disclosed to third parties not bound by this Privacy Policy only in non-personally-identifying, aggregated form.
  • Contests, Giveaways and other Promotions. From time to time, we may offer you the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with promotions will be subject to the terms of the promotion, not this Privacy Policy. You will be given the option to consent to the use of your Personal Data at the time you sign up for the promotion. You will not be required to participate in any promotion.
  • Employees, Third-Party Processors and Third-Party Service Providers. We will disclose Personal Information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers who process Personal Information on our behalf, participate with us in the provision or operation of the Site or the Services such as analytics providers, or hosting provider, or provide you with services, as described in Section 1.3 below. Transfers of Consumers’ Personal Information to subsequent third parties are covered by the service agreements with our clients. In the event of the transfer of Personal Information to a non-EU country, Persado uses standard contractual clauses to protect Personal Information.
  • By Law, to Protect Rights and to Comply with Our Policies. We disclose Personal Data:
    • to comply with legal or regulatory obligations;
    • to protect the property or other rights of us, other users or third parties;
    • if we believe that you have abused the Site or our Services or have otherwise violated applicable laws;
    • to any other third party with your prior consent.
  • Business Transfers. We may transfer all Personal Information in our possession to a successor entity in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets.
  • Marketing Communications. With your consent, we may email you about products and services that we believe may be of interest to you. You can opt-out at any time by either following the instructions contained in the email message to unsubscribe, or you can send us a message at infosec@persado.com, and request that you be unsubscribed. Unless you tell us otherwise, you will be unsubscribed from the email address used to send the message.If you want to have your account deleted in its entirety, you may send a message to infosec@persado.com, requesting that your account be deleted. We will delete your account and any information that personally identifies you. Please note that Persado will not delete your information if it reasonably believes it has a legal obligation to retain it, as outlined in Section 3.
  • Testimonials. We display personal testimonials and other endorsements of satisfied customers on our Site. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at the contact information provided in Section 10 below.
  • Social Media Features. Our Site includes social media features, such as the Facebook Like button and social media widgets. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy or notice of the company providing it.

 

1.2. PRIVACY PRACTICES SPECIFIC TO TECHNICAL INFORMATION

  1. COLLECTION AND TYPES OF TECHNICAL INFORMATION

Like most web sites or apps, we use automatic data collection technology when you use the Site and our Services to record information that identifies your computer, to track your use of our Site and our Services, and to collect certain basic information about you and your usage habits. We collect this Technical Information by using Cookies and pixel tags (also called web beacons or Clear Gifs).

This information may include:

  • information about your operating system;
  • your IP addresses;
  • browser type, language and geography;
  • referring and exit pages and URLs;
  • keywords;
  • date and time;
  • amount of time spent on particular pages;
  • what sections of the Site you visit;
  • similar information concerning your use of the the Site or our Services;
  • cookie identifiers;
  • Pseudonymized user ids processed through our Persado API (user ids are not identifiable).
  1. USE OF TECHNICAL INFORMATION

We may use Technical Information as follows:

  • To help us better understand how the Site and our Services are being used.
  • To identify patterns and trends in usage, so we are able to better design the Site and our Services to improve your experiences, both in terms of content and ease of use.
  • As necessary, to link information gathered by automatic data collection to Personal Information. Automatic data collection may be performed by us or on our behalf by our service providers.
  • Along with Cookies and other information to enable us to customize your user experience. To find out more about Cookies, please review our Cookie Policy, in Section 2.
  • For analytics and to provide reports on our Services performance (i.e. browser type, geography, device). All analytics are anonymized.
  • Through our Persado API, user ids to decide which random content users will get, both on initial interactions and return or repeat interactions with our Services.
  1. HOW WE SHARE YOUR TECHNICAL INFORMATION

We may share Technical Information in the following circumstances:

  • To provide our Services.
  • By Law, to Protect Rights and to Comply with Our Policies. We disclose Technical Information:
    • to comply with legal or regulatory obligations;
    • to protect the property or other rights of us, other users or third parties;
    • if we have reason to believe that you have abused the Site or our Services or have otherwise violated applicable laws.
  • Business Transfers. We may transfer all Technical Information in our possession to a successor entity in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets.
  • We work with a number of trusted service providers to process your Technical Information for online and digital advertising purposes.
  • From time to time, we may also release aggregated and anonymized Technical Information gathered from the Site and our Services, such as by publishing a report on trends in the usage of the Site and our Services.
  • Employees, Third-Party Processors and Third-Party Service Providers. We will disclose Technical Information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers who process Technical Information on our behalf, participate with us in the provision or operation of the Site or the Services such as analytics providers, or hosting providers, or provide you with services, as described in Section 1.3 below. Transfers of Consumers’ Technical Information to subsequent third parties are covered by the service agreements with our clients. In the event of the transfer of Technical Information to a non-EU country, Persado uses standard contractual clauses to protect Technical Information.

 

1.3. INFORMATION COLLECTED BY THIRD PARTIES

  1. THIRD PARTY COLLECTION OF YOUR CREDIT CARD INFORMATION

If you choose to purchase our Services using a credit card, our third-party payment card processor (currently Merchant e-Solutions) will process your credit card. All such transactions are managed and will be governed by the Merchant e-Solutions privacy notice at https://www.merchante-solutions.com/pages/oma/nmes/nmes.html. We do not receive or store any payment card information. We receive a transaction “token” and a one-time user ID number from Merchant e-Solutions, so we can validate that the transaction has been successfully completed.

  1. THIRD PARTY COLLECTION OF INFORMATION FOR ANALYTICS PURPOSES

We may use third party companies to provide us with analytics information. These companies may collect Personal Data from you via our Site. Google is one of our third parties, and you can find out more information about what data Google collects and how they use and disclose it here: http://www.google.com/policies/privacy/.

  1. COOKIE POLICY

Our Site and Services use Cookies, in combination with pixels, local storage objects, and similar devices (collectively, “Cookies” unless otherwise noted) to distinguish you from other users of the Site and Services. This helps us provide you with a good experience, improve our service, and to personalize content to you.

This cookie policy (“Cookie Policy”) describes the types of Cookies we use on the Site and in the Services, and our purposes for using them.

If you have questions about this Cookie Policy, please contact us at infosec@persado.com. For more information about our privacy practices, please see the Section 1 above.

 

2.1. COOKIE & AUTOMATED DATA COLLECTION DEFINITIONS

Cookies: A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device, which is like computer memory.

First and third-party Cookies: whether a cookie is ‘first’ or ‘third’ party refers to the domain placing the cookie.

First-party Cookies are those set by a website that is being visited by the user at the time (e.g. Cookies placed by a website domain).

Third-party Cookies are Cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third-party cookie.

Persistent Cookies: these Cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

Session Cookies: these Cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session Cookies are created temporarily. Once you close the browser, all session Cookies are deleted.

Clear Gifs: Clear Gifs are tiny graphics with a unique identifier, similar in function to Cookies, and are used to track the online movements of web site and app users. It is usually invisible to you but allows site and app operators to check whether you have viewed a particular web page or email communication.

 

2.2. WHY WE USE COOKIES AND AUTOMATED DATA COLLECTION

We may use First-Party Cookies and Third-Party Cookies to track the pages that you visit during each Site session, as well as when you use our Services, both to help us improve your experience and to help us understand how this Site or our Services are being used. If you’d like to learn how to manage these Cookies and choose whether or not to receive information of different types, please see the section 2.4 below.

  • Clear Gifs. We may place Clear Gifs on pages of the Site, within our Services and in emails we send to you. You may not decline Clear Gifs. However, you may render them ineffective by declining all Cookies or modifying your browser setting to notify you each time a cookie is tendered and permit you to accept or decline Cookies on an individual basis.
  • Third Parties’ Use of Clear Gifs and Cookies. This Site and our Services may include third-party advertising, links to other sites, and other content from third party businesses. The content posted by these parties will be reasonably identifiable as coming from a third party. These third-party sites, businesses, and advertisers, or advertising companies working on their behalf, sometimes use Clear Gifs and Cookies to measure the effectiveness of their ads, personalize or optimize advertising content and to track users who link from their respective sites to the Site or to our Services, but this third-party technology does not permit them to access your Personal Data. We do not have access to or control over Clear Gifs or Cookies that these third parties may use, and the information practices of these advertisers and third-party websites or businesses are not covered by this Privacy Policy but are covered by their respective privacy policies as is described in more detail in Section 7 below.
  • Log Files. 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 clickstream data.
  • Cookies or Similar Tracking Technologies. Technologies are used by us and our marketing partners, affiliates, analytics or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

 

2.3. WHEN DO WE REQUIRE YOUR CONSENT

All Cookies require your consent.

We request your consent before placing Cookies on your device. You can give your consent by clicking on the appropriate button on the banner displayed to you. If you do not wish to give consent or wish to withdraw your consent to any Cookies at any time, you will need to delete, and block or disable Cookies via your browser settings; see below for more information on how to do this. Please note that disabling these Cookies will affect the functionality of the Site and our Services.

2.4. HOW TO MANAGE YOUR COOKIES

  1. HOW TO DELETE AND BLOCK OUR COOKIES

Most web browsers allow some control of most Cookies through the browser settings. However, if you use your browser settings to block all Cookies (including strictly necessary Cookies), you may not be able to access all or parts of our Site or Services. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies as soon as you visit the Site or utilize applicable Services.

  1. CHANGING YOUR COOKIE SETTINGS

The browser settings for changing your Cookies settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise you should use the ‘Help’ option in your internet browser for more details.

  1. THIRD PARTIES’ USE OF CLEAR GIFS AND COOKIES

If you wish to not have Cookies or clear gifs 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. Some third-party advertising companies may provide a mechanism to opt-out of their technology. For more information about these partners and links to their privacy policies, please view each third party’s site.

  1. MORE INFORMATION

To find out more about Cookies, including how to see what Cookies have been set and how to manage and delete them, visit www.aboutcookies.org.

2.5. ONLINE TRACKING THROUGH THE PERSADO API

For online tracking through our Persado API, we adhere to the following guidelines:

  • Pseudonymization of user-ids; no other information is collected.
  • Exclusion of any query parameters from tracking (to avoid personal information).
  • Always configure our script with ‘respectdonottrack’ parameter enabled.
  • Provide guidelines to partners that enable our tracking code through their tag management system.
  1. SECURITY & RETENTION

We maintain appropriate administrative, technical and physical safeguards to protect and secure your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, both during transmission and once it is received. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, email sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via email. As described below in Section 8, any transfers of Personal Data outside of the EU will be on the basis of our Privacy Shield membership or using the Standard Contractual Clauses.

We will retain Personal Data for as long necessary to provide our Services, comply with our legal obligations, resolve disputes, and enforce our agreements, and for the other purposes outlined in this Privacy Policy. When your Personal Data is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you.

Certain Technical Information, and in some cases, anonymized Personal Information, may persist in copies made for backup and business continuity purposes.

  1. YOUR RIGHTS

We will collect, store and process your Personal Data in accordance with your rights under any applicable data protection laws. Under certain circumstances, you have the following rights in relation to your Personal Data:

  • Withdraw Consent: Where you have given us consent to process your Personal Data, you have the right to withdraw that consent at any time. If you wish to withdraw your consent to processing, please contact us using the details provided in Section 10.
  • Data Access: you can request copies of your Personal Information (where the system allows it)
    • We have no direct relationship with Consumers whose Personal Data we may process. A Consumer who seeks access, or who seeks to correct, amend, or delete Personal Data should direct his query to our client, the Data Controller. If requested to remove data by the Data Controller, we will respond within a reasonable timeframe.
  • Rectification: you can request a change to your personal data
    • we want to ensure the Personal Data we hold is accurate and up to date. If you think that any information about you is incorrect or incomplete, please let us know.

 

  • Erasure / The right to be forgotten: you can request the erasure of your Personal Data
  • Restriction of processing: you can request us to restrict the processing of the Personal Data we hold about you.
  • Right to object: You can object to us processing Personal Data relating to you.
  • Data Portability: you can request the transfer of your Personal Data directly to another organization, or to obtain certain Personal Data from us in a format that can be transferred electronically to a third party
  • Automated Decision making: you can object to this type of processing

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and Services. However, we will keep you informed as to the actions that we can take, when you make your request.

You can contact us at the address provided in Section 10 to update, amend, correct your information.

If you wish to enforce any of your rights under applicable data protection laws, then please contact us at the address provided in Section 10. We will respond to your request by no later than one month.

  1. IMPORTANT INFORMATION FOR NON-U.S. RESIDENTS

If you are located outside of the United States, please be aware that any information you provide to us may be transferred to and stored in the United States. By providing us with any information, you consent to this transfer. We comply with the Privacy Shield Principles for all onward transfers of Personal Data from the EU. You can find out more in Section 8.

  1. DATA INTEGRITY

We will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you as set forth in this Privacy Policy. We will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current.

  1. COMPLAINTS

If you are concerned that we have not complied with your legal rights under applicable data protection laws, you may contact your local data protection supervisory authority.

  1. CHILDREN

The Site and our Services are not intended for persons under 13 years of age. We do not knowingly collect Personal Data from persons under the age of 13. If you are under 13, please do not give us any Personal Data. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Data through the internet without their permission. If you have reason to believe that a person under the age of 13 has provided Personal Data or any other information or content to us, please email us at infosec@persado.com, and we will endeavor to delete it from our databases.

  1. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. Because of changes in technology and the growth and development of our business, or for other business reasons, we may need to change this Privacy Policy from time to time. We will post a copy of the new policy with its effective date on this Site if this Privacy Policy is revised (and may alert you by email if you have given us your email address).

  1. THIRD PARTY LINKS AND PRODUCTS

The Site and our Services may contain links to third party sites. We do not control or endorse such third-party sites, and we are not responsible for the privacy practices of such sites.

Third parties are under no obligation to comply with this Privacy Policy with respect to Personal Data that you provide directly to those third parties or that those third parties collect for themselves. This Privacy Policy does not apply to information provided to third-party sites or gathered by the third parties that operate them. Before visiting a third-party site, whether by means of a link on our Site or otherwise, and before providing any Personal Data to any third party, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that site, and should take those steps necessary to your discretion, to protect your privacy.

  1. EU – U.S. PRIVACY SHIELD

Persado participates in and is self-certified in compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all Personal Data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the applicable Privacy Shield Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list.

Persado is responsible for the processing of Personal Data it receives and then transfers under the Privacy Shield Framework to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, including the onward transfer liability provisions.

With respect to Personal Data collected from the EU through our Site or Services, Persado offers you the option as required under the applicable Privacy Shield principle to choose (opt-out) whether this Personal Data is (i) disclosed to a third party Controller or (ii) used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. To exercise this option, please contact Persado at the address provided in Section 10.

With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, Persado is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. 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.

  1. ENFORCEMENT

If we become aware that the security of the Site or our Services has been compromised or your Personal Data has been disclosed to unrelated third parties as a result of external activity, including but not limited to security attacks or fraud, we reserve the right to take reasonable appropriate measures, including but not limited to, investigation and reporting, and notification to and cooperation with law enforcement authorities.

If we become aware that your Personal Data has been disclosed in a manner not permitted by this Privacy Policy, we will make reasonable efforts to notify you, as soon as reasonably possible and as permitted by law, of what Personal Data has been disclosed, to the extent that we know this information.

Individuals who wish to file a complaint or who take issue with our Privacy Policy should direct such communication via email or written communication at the address provided in Section 10 below. Filing a complaint in English will expedite the process. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the principles contained in this Privacy Policy. You also have the right to lodge a complaint with a data protection supervisory authority as described in Section 4 above.

If you are unable to resolve the issue directly with us, you may file, free of charge, a complaint with our independent dispute resolution provider, JAMS located in the United States. JAMS’s Dispute Resolution process is only available in English. For more information about JAMS dispute resolution process or to file a complaint, please visit: https://www.jamsadr.com/EU-us-privacy-shield.

We are also subject to the jurisdiction of the US Federal Trade Commission. The Federal Trade Commission may be contacted at the following address:

Federal Trade Commission

Attn: Consumer Response Center

600 Pennsylvania Avenue NW

Washington, DC 20580

consumerline@ftc.gov

www.ftc.gov

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint

  1. HOW TO CONTACT US

If you have questions about our Privacy & Cookie Policy, please contact us at:

Persado, Inc.

11 East 26th Street

New York, NY 10010, U.S.A.

infosec@persado.com

  1. DEFINITIONS

Applicable data protection law: means any state, federal or foreign law(s), rule(s) or regulation(s) applicable to the Addendum, the Agreement, or the Processing, as well as applicable Industry Standards, including those concerning privacy, data protection, confidentiality, information security, availability and integrity, or the handling or processing of Personal Data. Applicable Laws expressly include, if applicable, the United Kingdom Data Protection Act 1998 (the “UK Data Protection Act”), including any superseding regulation, the EU-US Privacy Shield Framework and Principles issued by the U.S. Department of Commerce, both available at https://www.privacyshield.gov/EU-US-Framework(collectively the “Privacy Shield Framework and Principles”), EU Directive 95/46/EC (the “Data Directive”), and, when effective, the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), EU Directive 2002/58/EC (the “ePrivacy Directive”), and, when effective, any regulation expressly superseding the ePrivacy Directive, as well as the laws, rules, and regulations of each nation in the European Economic Area (“Member State Law(s)”).

Clear Gifs: are tiny graphics with a unique identifier, similar in function to Cookies, and are used to track the online movements of web site and app users. It is usually invisible to you but allows site and app operators to check whether you have viewed a particular web page or email communication.

Consumer: means the end customers of our customers. In most cases, we do not have any relationship with Consumers and only process Personal Data on behalf of our customers.

Controller or Data Controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Cookies: a cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device, which is like computer memory.

Processor or Data Processor: means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

Personal Data: consists of Personal Information and Technical Information.

Personal Information: consists of information such as your name, email address and telephone number.

Technical Information: consists of usage data and other technical information about how you use our Site and our Services.