Privacy

Last Updated December 05, 2019

1. Introduction

This Policy outlines how we protect the privacy of people who:

• visit our Websites (“Website Visitors”)
• register to use the products and services which we market for subscription (the “Products and Service(s)”)
• attend or register to attend sponsored events or other events at which takes part (“Attendees”).

For the purposes of this Policy, the term, “Websites” ” refers to www.VisibleThread.com. It also refers to the other VisibleThread operated websites, and any other websites that link to this Policy.

2. Scope Of This Policy

In this Policy, we define personal information as information about an identifiable person.

You can identify a person with information such as:

• a name
• an identification (I.D) number
• location data
• an online identifier.

Other personal data may include:

• address
• phone number
• email address.

Our Websites may contain links to other websites. And therefore to the privacy statements of these websites, their information practices and the content they use. If you have any concerns, take the time to read the privacy statements of these other websites.

This Policy does not apply to our security and privacy practices concerning your access to our Products and Services. This Policy does, however, apply to the data we collect when you register for our Products and Services.

These security and privacy practices include how we collect and use electronic data, text messages and communications. They also include any other materials submitted to and stored within our Products and Services by you (Service Data). All security and privacy practices are detailed in and governed by our Subscription Agreements (“Subscription Agreement”).

Subscribers to our Services may upload documents or specify webpages for analysis. They may also use our Services to analyze plain text. Subscribers are responsible for the correct handling of personal information uploaded in these documents or text.

3. How We Handle Information That You Provide To Us

Account and Registration Information:

When you register for an account, we will ask for your personal information. This may include your name, address, phone number and email address. We may also ask for your company name and website name, where relevant.

We also ask for personal information from anyone you allow to log into our Services through your Account.

We will not ask for your credit card details if you sign up for a free trial. We will only ask for them if you decide to continue with a paid subscription to our Services. We use a third-party company to manage credit card processing. We do not permit them to store, keep or use your data for anything but processing payments on our behalf.

We refer to any information described above as “Account Information” for the purposes of this Policy. By providing us with Account Information, you are telling us that you are the owner of that personal data. Or the owner has given you permission to give the data to us.

Other Submissions:

We ask for personal information from you when you submit web forms on our Websites. We will also collect personal information as you use interactive features of the Websites, including:

• participation in surveys
• contests
• promotions
• sweepstakes
• requesting customer support
• or otherwise communicating with us.

Attendee Information:

We may ask for personal information when you register and/or attend events at which any member of VisibleThread participates.

Mobile Application:

When you download and use our Services, we collect data of the device and operating system used.

4. Information That We Collect From You On Our Websites

Cookies and Other Tracking Technologies:

We may use cookies from time to time. Cookies are small text files a website can use to recognize a repeat visitor to the Website. We use cookies for various reasons. Cookies enable us to give you a better experience. This is done by allowing us to understand what areas of this site are of interest to our users.

Only the VisibleThread website can read cookies from VisibleThread. You can set to reject cookies if you don’t not want us to deploy them in your browser. You can also set your browser to notify you when a website tries to use cookies. If you choose to disable cookies in your browser, you can still access most of this site. However, this may affect your ability to use some of the products and/or services on this site.

We may use web beacons, tags, and scripts on our Websites, in email or other electronic communications we send. These assist us in delivering cookies, counting Website visits, and understanding if a campaign was effective. They also allow us to determine if you have opened an email and acted upon it. We may get reports based on the use of these technologies by third-party service providers.

Logs:

We gather certain information and store it in log files when you interact with our Websites and Services. This information includes:

• internet protocol (IP) addresses
• browser type
• internet service provider
• URLs of referring/exit pages
• operating system
• date/time stamp
• information you search for
• locale and language preferences
• I.D. numbers associated with your devices
• your mobile carrier
• system configuration data

We may connect personal information to information gathered in our log files to improve our Websites and Services. In such a case, we would treat the combined information in line with this Policy.

Analytics:

We collect analytics information when you use the Websites to help us improve them.

5. Information Collected From Other Sources

Social Media Widgets:

The Websites may include social media features such as Facebook “Like” and “Share” buttons. The Websites may also run interactive mini-programs which collect your Internet Protocol address and pages you visit. They may also set a cookie to enable the feature to function. Social media features and widgets are either hosted by a third party or hosted on the Websites. The privacy statements of these services govern your interactions with these features.

Information From Third Party Services:

We may also obtain other information from third parties and combine that with information we collect through our Websites. For example, you can login to the Services using Facebook Connect or an Open ID provider. These are further described below.

If you log into our Services through social media, we may have access to certain information.

Any access to data from a third-party service is in line with the authorization procedures determined by that service. By allowing us to connect with a third-party service, you authorize us to access and store your:

• name,
• email address(es),
• current city,
• profile picture URL,
• and other personal information that the third-party service gives to us.

You also authorize us to use and disclose this information in line with this Policy. You should check your privacy settings on these third-party services to understand and update them, if required.

Single Sign-On:

You can log into certain Services using sign-in services such as Facebook Connect or an Open ID provider. These services will

• authenticate your identity,
• give you the option to share certain personal information with us
• and pre-populate our sign-up form.
• Services like Facebook Connect give you the option to post about your activities to others in your network.

6. How We Use The Information We Collect

General Uses:

We may use the information we collect about you for a variety of purposes, including to;

1. provide, improve, and promote the Services
2. enable you to access and use the Services
3. process and complete transactions, and send related data, including purchase confirmations and invoices
4. send transactional messages, including responses to your comments, questions, and requests. Provide customer service and support; and send technical notices, updates, security alerts, and support and administrative messages
5. send promotional communications, such as information about products and services, features, surveys, newsletters, offers, promotions, contests, and events. We may also provide other news or information about us and our partners. You can opt-out of receiving marketing communications from us by contacting us at info@visiblethread.com. You can also follow the unsubscribe instructions included in our marketing communications
6. process and deliver contest or sweepstakes entries and rewards
7. monitor and analyze trends, usage, and activities concerning the Websites and Services and for marketing purposes
8. investigate illegal activities such as fraudulent transactions and unauthorized access to the Services,
9. personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences,
10. perform other purposes for which we obtain your consent.

Legal Basis for Processing (EEA only):

Our legal basis for collecting and using personal information from the EEA will depend on the information concerned. It will also depend on the context in which we collect it. However, we will collect personal information from you where:

1. we have your consent to do so
2. where we need the personal information to perform a contract with you. For example, to deliver the Services you have requested, or
3. where the processing is in our or a third party’s legitimate interest (not overridden by your data protection interests or fundamental rights and freedoms).

In some cases, we may also have a legal obligation to collect personal information from you. We may otherwise need the personal information to protect your vital interests or those of another person.

You have the right to decline your consent for us to process your personal information. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.

We will make it clear when we need your personal information for legal requirements or to perform a contract. And we will advise you whether the provision of your data is mandatory or not. We will also let you know the possible consequences if you do not give your data.

For further information concerning the legal basis on which we collect and use your personal information, please contact info@visiblethread.com.

7. Sharing Of Information Collected

Third-Party Service Providers:

We may share information, including personal information, with our third-party service providers. They provide hosting and maintenance of our Websites, application development, backup, storage, payment processing, analytics, and other services. They may have access to / or process your data to provide these services for us. We do not permit them to use this information for any purpose other than the services provided to us.

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights.

Public authorities may ask to disclose personal information in response to lawful requests. This may include meeting national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process. Or to exercise our legal rights or defend against legal claims.

We may also share data to investigate, prevent, or take action regarding:

• illegal activities
• suspected fraud
• situations involving potential threats to the physical safety of any person
• violations of our Subscription Agreement
• or as otherwise required by law.

Testimonials:

From time to time, we may post testimonials on the Websites that may contain personal information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at info@visiblethread.com.

Referrals:

If you tell a friend about our products and services, we will ask for their name and email address. We will send your friend an email inviting them to visit the Websites. We will store this data for sending an initial email, tracking referral program success and other marketing activities. Your referral may contact us at info@visiblethread.com to request that we remove their data from our database.

Community Forums:

The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). Anyone who accesses an Interactive Area can read, collect, and use any information posted. To request removal of your personal information from an Interactive Area, contact us at info@visiblethread.com. If we are unable to remove your personal information for any reason, we will let you know why.

VisibleThread Sharing:

We may share information, including personal information, with any member of VisibleThread.

With Your Consent:

We may also share personal information with third parties when we have your consent to do so.

8. International Transfer Of Information Collected

VisibleThread is a global company. We store personal information about Website Visitors and Subscribers within the EEA, the US and other countries and territories. To facilitate our global operations, we may transfer and access personal information from around the world.

We collect data from all our users including visitors from regions with laws governing data collection and use. By providing this personal information you acknowledge that we may transfer it to other jurisdictions in which we operate.

9. Communications Preferences

We offer those who give personal contact information a means to choose how we use the information provided. You may unsubscribe from non-transactional communications by clicking on the link located on the bottom of our marketing emails. You can also send a request to info@visiblethread.com.

10. How Long We Retain Your Personal Information

We will keep your personal information until we fulfil the purposes outlined in this Policy. Legal authorities may need us to keep your data for a longer period. For example, for tax, accounting, or other legal requirements.

When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it. This may not be possible if we have stored your personal information in backup archives, for example. In this case, we will store and isolate it from any further processing until deletion is possible.

11. Your Privacy Rights

We can tell you whether we hold, or process for a third party any of your personal information. To request this information please contact us at info@visiblethread.com. Subscribers to our Services may update or change their Account Information by editing their profile or organization record. You can also contact support@visiblethread.com for more detailed instructions. To make a request to have personal information maintained by us returned to you or removed, please email support@visiblethread.com. We will handle requests to access, change, or remove your information within thirty (30) days.

Additional Rights for EEA and Certain Other Regions:

Subscribers from places such as the EEA may have additional rights available to you under applicable laws. These include;

• Right of erasure. In certain circumstances, you may have a right to erase personal information that we hold about you. For example, if it is no longer necessary to the purposes for which we collected it. However, we may keep certain data for record keeping, to complete transactions or to follow legal obligations.
• Right to object to processing. You may have the right to request that we stop processing your personal information and/or stop sending marketing communications.
• Right to restrict processing. You may have the right to request that we restrict processing of your personal information in certain circumstances. For example, where you believe that the personal information we hold about you is incorrect or unlawfully held.
• Right to data portability. You may have the right to request your personal information in a structured, machine readable and commonly used format. You may also request that we transfer the personal information to another data controller without hindrance.

If you would like to exercise such rights, please contact us at info@visiblethread.com. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

You have the right to complain to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority.

12. Children’s Personal Information

We do not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please don’t submit any personal information through our Websites or Services. We encourage parents and legal guardians to keep an eye on their children’s Internet usage. Parents can also help by instructing children to never give personal information through Websites or Services without their permission. If you think a child has provided personal information through our Websites or Services, please contact us at info@visiblethread.com. We will use commercially reasonable efforts to delete that information.

13. Business Transactions

It is possible that a person or entity may acquire some or all of our business, stocks, or assets. In this case, we may assign this Policy, your account, personal information, and data with whom we merge.

14. Supplemental Terms and Conditions for Certain Regions

Brazil:

Personal information collected, stored, used, and/or processed by VisibleThread is in line with Brazilian Law No. 12,965/2014. By accessing our Website/Services, you consent to the collection, use, storage, and processing of your personal information.

Australia:

Personal information collected, stored, used, and/or processed by VisibleThread complies with the Australian Privacy Act 1988 (Commonwealth).

You may contact the Office of the Australian Information Commissioner (OAIC) if you are not happy with how we handled your complaint. You can contact the OAIC using the methods listed on their website at http://www.oaic.gov.au. Alternatively, you may request that we pass on the details of your complaint to the OAIC directly.

New Zealand:

Personal information collected, stored, used, and/or processed by VisibleThread complies with NZIPPs (New Zealand’s Privacy Act 1993 and its 12 Information Privacy Principles).

Singapore:

Personal information collected, stored, used, and/or processed by VisibleThread complies with PDPA (Personal Data Protection Act 2012 of Singapore).

Canada:

Personal information collected, stored, used, and/or processed by VisibleThread complies with PIPEDA (Personal Information Protection and Electronic Documents Act of Canada).

15. Changes To This Policy

We will post a prominent notice on the Websites prior to any changes to this Policy becoming effective. We encourage you to review this page for the latest information on our privacy practices. By continuing to use the Websites or Services, you agree to such changes to this Policy. If you do not accept the terms of this Policy, you should discontinue use of the Websites and Services.

16. Contact Us

If you have questions regarding this Policy or about VisibleThread’s privacy practices, please contact us by email at info@visiblethread.com

This privacy policy is subject to change without notice.