Last Revised: July 5, 2021
2. PERSONAL INFORMATION COLLECTED THROUGH PLATFORM
“Personal information,” also known as personal data or personally identifiable information, is any information related to an identifiable person. When you register for an Account, purchase a one-time or subscribe for a monthly Service, or fill out one of our questionnaires (including when you fill out a form to book a free consultation with us), we may collect the following personal information from you: email, first name, last name, company name, mailing address, email address, phone number, and any personal information you choose to provide to us voluntarily.
3. NON-PERSONAL OR AGGREGATE INFORMATION WE MAY COLLECT
We may collect data which is non-personal, anonymous, or pseudonymous, including, but not limited to, time zone you are in, information on how you first heard about us, browser type, website usage history, number of logins, login times, and time/date of login.
4. PURPOSES FOR WHICH WE USE INFORMATION ABOUT YOU
We only use information about you to support your experience throughout the Platform or to communicate with you about our Services. In particular, we collect information about you:
- to recognize you as a registered user;
- to process your payments;
- to respond to your inquiries or requests;
- to provide customer support;
- to conduct market research;
- to comply with all applicable laws or if we are required by law or by a court order to do so;
- to analyze non-personal or aggregate information for the sake of Platform improvement; and
- to transfer information in connection with the sale or merger or change of control of the Company.
We reserve the right to use and disclose non-personal information and anonymous aggregate statistics for any purpose and to any third party at our sole discretion.
5. BUSINESS TRANSFERS
We may sell, transfer or otherwise share some or all of our assets, including your personal information, in connection with a merger, acquisition, reorganization, bankruptcy, or sale of assets.
6. PHONE CALLS
When you are in contact with us by phone, the call may be monitored or recorded for quality assurance purposes. Your continued participation in any telephone conversation will serve as your express consent to be monitored or recorded.
7. FEEDBACK & REVIEWS
If you submit any feedback (either about the Platform, Company or Services) or (“Feedback”), you assign to the Company all rights in the Feedback and agree that the Company shall have the right to use such Feedback and related information in any manner it deems appropriate. We will treat any Feedback you provide to us as non-confidential and non-proprietary. You agree that you will not submit to us any information or ideas that you consider to be confidential or proprietary.
8. MINORS (CHILDREN) POLICY
We are committed to protecting children’s personal information and comply with the strictest privacy laws out there. We do not knowingly collect or solicit personal information from anyone under the age of majority. If you are a minor, please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from a minor, we will delete that information as quickly as possible. Please contact us if you believe we may have collected information from a minor.
9. HOW LONG WE KEEP YOUR INFORMATION
10. DATA STORAGE
The security of your information is very important to us. We apply all reasonable security measures and comply with the industry standards to protect your personal information (including, preventing the loss, misuse, unauthorized access, disclosure, alteration and destruction of your personal information).
Notably, access to the Platform’s database with your personal information is held behind administrative logins and managed, controlled and limited to authorized website administrators and support technicians only. Data transmitted between browser and application servers is encrypted using an HTTPS/SSL certificate. We do not collect or store your passwords (however, we may help you restore your password when needed). We use XSRF against cross-domain attacks. Data is backed up daily. The Platform’s server software is updated regularly to ensure we are running the latest and safest software (where applicable and depending on compatibility). The server’s firewall is configured to prevent unauthorized access, and activity is automatically monitored to detect and ban malicious activity.
Please be aware, however, that despite our efforts, no security measures are impenetrable. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your personal information, we cannot ensure and do not warrant the security of any information you transmit to us.
12. YOUR RIGHTS UNDER GDPR
The European General Data Protection Regulation (“GDPR”) is a regulation in EU law on data protection and privacy for all natural persons accessing the Internet from the European Union and the European Economic Area, whatever their nationality or place of residence is. It also addresses the transfer of personal data outside the EU and EEA areas. Our collection, processing and protecting of personal information of those who access the Platform from a European country, is compliant with GDPR.
If you are accessing and using the Platform from the European Union and the European Economic Area, you have the following rights with regard to your personal information:
- the right of access (you can request us to provide you verbally or in writing with the type of information we store about you and we have a month to respond to your request);
- the right to rectify (amend/correct) any personal information about you that is inaccurate;
- the right to erasure (some conditions apply, see Data Retention section below);
- the right to restrict processing your personal information, however, if you restrict us from processing a part of your personal information that is essential to our provision of the Platform, you may be asked to terminate your Account and stop using the Platform;
- the right to data portability (the right to data portability allows users of the Platform to obtain and reuse their personal information for their own purposes across different services; you may request us to transmit your personal information directly from our servers to another company’s servers and we will do so if it is technically feasible);
- the right to object (for example, you have an absolute right to stop us from using your personal information for direct marketing – read our opt-out instructions below; you may express your objection verbally or in writing and we have a month to respond to any such objection; we might still continue processing your personal information if we are able to show that we have a compelling reason for doing so);
- the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or that affects you significantly.
We represent and warrant that your personal information is:
- processed lawfully, fairly and transparently;
- collected only for specific legitimate purposes;
- collection of personal data is adequate, relevant and limited to what is necessary;
- accurate and kept up to date (with your help);
- stored only as long as is necessary; and
- is secure and kept in confidence.
Data Retention: Generally, your personal information will be erased when (i) it is no longer needed for its original processing purpose, (ii) you withdraw your consent for us to store by deleting your Account, (iii) there is no preferential justified reason for the processing of your personal information and you object to our processing of your personal information, or (iv) erasure of your personal information is required in order to fulfil a statutory obligation under the EU law or the right of the EU Member States. Therefore, we will make sure your personal information will be erased under all of the above-mentioned circumstances. You may request us to erase your personal information verbally or in writing and we have one (1) month to respond to any such request.
Data Breach Notification: Should there be a personal data breach leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed, we will notify you and appropriate supervisory authority without undue delay and, where feasible, not later than seventy-two (72) hours after having become aware of it.
13. YOUR RIGHTS UNDER LGPD
Lei Geral de Proteção de Dados (“LGPD”) is the Brazilian general data protection law, which applies to businesses that process the personal data of users located in Brazil. LGPD establishes rules on collecting, handling, storing and sharing of personal data managed by organizations.
According to the article 18 of LGPD, individuals have the following nine rights over their data processing:
- The right to receive a confirmation about processing of their personal data;
- The right to access their personal data;
- The right to correct incomplete, inaccurate or out-of-date personal data;
- The right to anonymize, block or delete unnecessary or excessive data or data processed in noncompliance with the provisions of LGPD;
- The right of portability of the data to another service or product provider, by means of an express request and subject to commercial and industrial secrecy, pursuant to the regulation of the controlling agency;
- The right to delete their personal data;
- The right to know who their data is being shared with (e.g., third parties, sub-processors, public, and private entities);
- The right to know how to deny consent and what would be the consequences of denying consent to collect personal data; and
- The right to revoke consent.
14. MARKETING EMAILS, OTHER COMMUNICATIONS & OPT-OUT OPTION
15. COOKIES POLICY
A “cookie” is a small piece of data sent along with pages of a website and stored by the user’s web browser on the user’s computer or mobile device. Cookies were designed to be a reliable mechanism for websites to remember certain information (such as items added in a shopping cart) or to record a user’s browsing activity (including clicking particular buttons, logging in, or recording which pages were visited in the past). Cookies are intended to help you access a website faster and more efficiently, because they can store information to help you enter a website without having to log in. In effect, cookies tell the website that your browser has been to the website before. It does not need to know your exact identity. Cookies can also be used to remember arbitrary pieces of information that the user previously entered into form fields such as names, addresses, passwords, and credit card numbers.
Browsers may accept or reject cookies automatically but allow you to change these settings. The help menu on most browsers will tell you how to change your browser’s settings and how to have the browser notify you when you receive a new cookie, and how to disable cookies all together. You can also disable or delete cookies you have previously accepted if you wish to.
The following are examples of cookies that may be used on our Platform:
a) Strictly necessary cookies. These cookies are essential in order to enable you to move around the Platform and use its features.
b) Performance/analytic cookies. These cookies collect data about how visitors use our Platform, including the country from which the visitor is accessing the Platform. They allow us to recognize and count the number of visitors and to see how visitors move around the Platform when they are using it.
c) Functionality cookies. These are used to recognize you when you return to our Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
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