TABLE OF CONTENTS
- 1. The Type of Information the Site Collects
- 2. How the Site Uses and Shares Your Information
- 3. Local Device Storage and Tracking
- 4. How to Opt-Out of Third Party Tracking Technologies
- 5. Information Security and Notification
- 6. Kids and Parents/ California Customers – Your Privacy Rights
- 7. EU Customers
- 8. Data Protection Officer
C. Our servers may also automatically collect information about you, your online behavior and your computer, mobile or other device. The information collected may include, without limitation, the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of you and/or your computer, mobile or other device, as well as date/time stamp, IP address, pages visited, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data.
A. We use personally identifiable information you supply through the Site to provide you with the product, service, and/or content you have requested, including, by way of example, information on our job openings. We may also use the information to communicate with you about new features, products or services, employment opportunities, items we feel may be of interest to you and/or to improve our services that we offer by tailoring them to your needs.
B. Unless otherwise specified on the Site, we may share information about you and your computer, mobile or other device, including without limitation your Registration Information and other personally identifiable information, with our parent, subsidiaries, and affiliates and with carefully selected companies who we think may offer services and/or products that may be of interest to you. If you do not wish to have your personally identifiable information shared with third parties, contact our Data Protection Officer as described at the end of this document. If you do not wish to receive future commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive.
C. We may also allow access to our database by third parties that provide us with services, such as technical maintenance, market research, community and forums management, and other classified ads functionality, but only for the purpose of and to the extent necessary to provide those services.
D. We reserve the right to access, use, and share with others your personally identifiable information for purposes of health, safety and other matters of public interest.
E. We may also provide access to our database in order to cooperate with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process.
F. In addition, we reserve the right to use the information we collect about your computer, mobile or other device (including its geographic location), which may at times be able to identify you, for any lawful business purpose, including without limitation to help diagnose problems with our servers, to gather broad demographic information, analyze trends, track users’ movements around the Site, and to otherwise administer the Site. Geographic location information about you and/or your computer, mobile or other device may specifically be used to show you content and sponsored messaging based on geographic location.
G. We or our third party web analytics partners may gather certain information automatically and store it in log files or systems used by us. This information may include internet protocol (IP) addresses, device type, browser type, internet service provider (ISP), referring/exit pages, operating system, geolocation, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you as well as our marketing, analytics and Site functionality and to analyze trends and gather demographic information about our Site visitors.
H. We may collect and use your location based information for the purpose of optimizing your Site experience. We may share this information with our service providers for the purpose of providing and optimizing this service for our visitors. You may opt-out of location-based services at any time by editing the setting on your device.
I. We reserve the right to use, transfer, sell, and share aggregated, anonymous data about our users as a group for any lawful business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients and customers.
J. In addition, as our business changes, we may buy or sell various assets. In the event all or a portion of the assets owned or controlled by us, our parent or any subsidiary or affiliated entity are sold, assigned, transferred or acquired by another company (including, without limitation, via merger), the information from and/or about our Site’s users may be among the transferred assets.
K. We reserve the right to identify you from your Registration Information and/or to merge or co-mingle anonymous or non-personally identifiable data about you, your offline and online behavior, and/or your computer, mobile or other device (including its geographic location), with your Registration Information and/or other personally identifiable data for any lawful business purpose.
N. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Evergage is potentially liable.
A. The Site will at times place and/or store code or other types of information and/or devices (e.g., “cookies”) on your computer, mobile or other device (“Local Device Storage”). We may use Local Device Storage for any lawful business purpose, including without limitation to determine which of our messages have been opened by recipients so we can gauge the effectiveness of marketing campaigns, to control the display of ads, to track usage patterns, the movements of individual users, and your geographic location, to help diagnose problems with our servers, to gather broad demographic information, to analyze trends, to conduct research, to deliver editorial content, to record registration and personalization information, and to otherwise administer the Site. For example, if you register on any part of the Site and are given the option to save your username and password, we may provide this convenience to you via Local Device Storage. Local Device Storage may also collect and store your personally identifiable information, which may be shared with our parent, subsidiaries, and affiliates and other companies. In addition, we may use third party Sites such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Site's functionality. These third party service providers have their own privacy policies addressing how they use such information.
B. If you do not want Local Device Storage, your computer, mobile or other device may include an option that allows you to not accept it. However, if you disable Local Device Storage, some portions of the Site may not function properly.
C. In addition to Local Device Storage, we may use web beacons, web bugs, clear gifs, and similar technologies (collectively, together with Local Device Storage, the “Tracking Technologies”). We may use Tracking Technologies for all or some of the same lawful business purposes we describe above for use of Local Device Storage.
D. As discussed below, you may opt out of third-party tracking on the Site at any time. Also, we support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
A. The security of your Registration Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.
A. The Site is not intended for use by children, especially those under age 13. No one under age 18 is allowed to register for the Site or provide any personally identifiable information or use our social, community, and public discussion areas, photo and video galleries, bulletin boards, forums, chats, blogs, personal/job search and other classified ads, and elsewhere.
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As discussed above, if you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes or to find out more about your opt-out rights, please contact our Data Protection Officer as described below.
Data Protection Officer, Evergage, Inc. 212 Elm Street, Somerville, MA, 02144, USA. Alternatively, you can email us here.
Evergage Inc. has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Evergage is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
If you have any other concerns or questions about any aspect of this policy, please feel free to contact our Data Protection Officer as follows:
Data Protection Officer, Evergage, Inc. 212 Elm Street, Somerville, MA, 02144, USA. Alternatively, you can email us here.
As discussed above, you may opt-out of having your personally identifiable information shared with third parties for their marketing purposes. If you wish to exercise this right, please contact our Data Protection Officer and state that you want to opt-out of our sharing with third parties.
Also as discussed above, if you wish to request updates or changes to your information or your preferences regarding receiving future promotional messages from us, you may contact our Data Protection Officer.
Who are Evergage Clients?
Evergage Clients are financial service companies, ecommerce companies, travel companies, gaming companies, the marketing websites of B2B tech companies, Software-as-a-Service applications, support portals, and any digital website, web app or mobile app that wishes to use the Service (i) to understand how their End Users are using their services and (ii) to respond in real-time to their End Users by giving them a maximally helpful, relevant, individualized experiences.
A. What information does Evergage collect regarding End Users?
It is at Evergage Clients’ discretion what actions and information they collect from each End User. However, Evergage generally requires Evergage Clients to observe all applicable laws and regulations relating to the protection of data privacy and to only collect information that is necessary to improve Client Services and successfully serve their End Users.
One primary use of Evergage is to understand how End Users are using the Evergage Client’s service. Many Evergage Clients send us, on a per-user or per-visitor basis, a subset of the actions taken by each End User within such Evergage Clients’ services and when such actions were taken.
- For example, suppose John Doe used company XYZ’s document management system to upload a document, edit it, and share it with three friends. If XYZ was an Evergage Client, XYZ might collect and send to Evergage that John Doe edited a document at a certain time and that he has 5 documents in XYZ’s system. Later, XYZ might decide to also collect and send to Evergage when John shares a document and into what format he converted the document to share it. XYZ could use this information to improve their product and to email John Doe with training about better ways to share a document.
Another primary use case of the Service is to personalize the experience for End Users based off of the combination of their behavior and their attribute data.
- For example, suppose Jane Smith used company ABC’s ecommerce website to research furniture. If ABC was an Evergage client, ABC would use Evergage to track which pieces of furniture were of interest to Jane, and then to make it easy for Jane Smith to find those pieces again. ABC might also use Evergage to recommend to Jane Smith additional pieces of furniture that may be of interest or accessories that complement the pieces she is buying.
The data that Evergage Clients choose to send us is often not personally identifiable information, but may be personally identifiable information.
B. Does Evergage require Evergage Clients to inform the End User about their use of the Service?
C. How does Evergage use the information it collects?
The information Evergage collects on End User activities with Client Services is the property of the Evergage Client, not of Evergage. We store the data in a unique security domain for each Evergage Client. Our rules and algorithms process and analyze each Evergage Clients’ data separately to give that Evergage Client a better understanding of its End Users and the means to respond in real-time to the End User with a more relevant experience.
Evergage also aggregates information across Evergage Clients to (i) improve the Service, (ii) benchmark usage patterns and behavior for a particular Evergage Client and for Evergage Clients generally, (iii) publish interesting analysis of trends or behaviors and (iv) other similar uses.
D. Will Evergage provide information about you to anyone else?
Except as provided below in the sections entitled Information Disclosed Pursuant to Business Transfers and Information Disclosed for Our Protection and the Protection of Others, we never divulge End User data in a personally identifiable, unique or non-aggregated manner to anyone other than the Evergage Client on whose behalf we are collecting and analyzing its End User data.
E. How does Evergage make sure your information is secure?
Evergage takes the security and privacy of Evergage Client data and End User data very seriously. We use industry standard best practices to secure our systems and access to the data. Each Evergage Client’s data is kept separate from each other Evergage Client’s data. Each Evergage Client’s data flows through our system in a separate message queue, is stored in separate files on disk, and is a part of a unique security domain. Access to that security domain is protected by user authentication. However, no method of transmission over the Internet and no method of electronic storage is 100% secure. Therefore, while we strive to use industry standard best practices to protect your Personal Information, we cannot guarantee its absolute security.
Like many websites we sometimes employ “cookies,” small packets of data, which may include an anonymous unique identifier that are sent to a user’s browser from a website’s computer and stored on the user’s computer’s hard drive. The website placing the cookie on the user’s computer can then recognize the computer when the user navigates the website at a later time. For example, this allows us to remember user preferences and measure user behavior, information that Evergage Clients may then use to improve user interaction with their services.
Evergage makes use of first party cookies.
Evergage also provides a mobile SDK that most Evergage Clients use to integrate their mobile app with Evergage in the same way.
H. Are there ways that you can opt out of allowing an Evergage Client to collect data on your use of its service?
Yes. If you are an End User of an Evergage Client and do not wish for us to collect information about your use of that service, there are several options:
We have provided Evergage Clients with the ability to filter and dispose of usage data related to a particular End User’s user ID. If you would like to opt out of having your data sent to Evergage, please contact the Evergage Client directly. If you feel the Evergage Client is not responding satisfactorily to your request, please contact us here.
A. What information does Evergage collect on its Clients and how is it used?
We collect only data that is necessary to provide optimum service for our Clients. The information we gather enables us to personalize, improve and continue to operate the Service. To explain how we use and safeguard your data, let’s look at the types of information we collect:
- Usage Data: We make use of our own service to understand how Evergage Clients are using the Service so as to maximize your success with us, to personalize your experience, and to improve performance of the Service. The entire preceding section with respect to End User Information applies to Evergage Client’s employees own use of the Service.
- Account Information: When you create a Service account, you will provide us with certain personally identifiable information (“Personal Information”), such as your name, contact information, and account user name and password. We recognize that this information is very important to you and we promise we will never divulge any of your Personal Information to anyone without your permission except as described below in the Sections entitled Information Disclosed Pursuant to Business Transfers and Information Disclosed for Our Protection and the Protection of Others. Please note that we may use your Personal Information to contact you regarding your account and the Service.
- Email Communications: We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.
B. Changing or Deleting your Information:
If you are an Evergage Client, you may review, update, correct or delete the personally identifiable information in your Evergage account where it is inaccurate by contacting us. If you would like us to delete your Evergage account in our system, please contact us here with a request that we delete your personally identifiable information from our database. We will use commercially reasonable efforts to honor your request. If you request that your personally identifiable information be deleted from our records, there may be a brief delay in our processing that request, while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that your information be deleted, we reserve the right to terminate and/or limit your access to the Service. We may retain an archived copy of your records as required by law or for legitimate business purposes.
We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited email or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
A. Information Disclosed Pursuant to Business Transfers:
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Evergage or our assets may continue to use your Personal Information as set forth in this policy.
B. Information Disclosed for Our Protection and the Protection of Others:
We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce our Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
C. International Transfer
D. Third Party Practices
Our Service is not directed to children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us here. If we become aware that a child under the age of 13 has provided us with personally identifiable information, we will delete such information.
G. Questions or concerns?
If you have any questions or concerns regarding privacy using the Service, please send us a detailed message to us here. We will make every effort to resolve your concerns.