Effective on September 22, 2016
Extole complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. [Participant] has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view [Participant’s] certification, please visit http://www.export.gov/safeharbor.
Extole, Inc. participates in and has certified its 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 Framework’s applicable 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.
We are responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers 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 received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory 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.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Extole complies with the U.S.–Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland. Extole has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Extole’s certification, please visit http://www.export.gov/safeharbor/.
Except as described below, Extole does not collect or require users of its service, https://extole.com, to furnish personal information. Like most websites, Extole collects non-personal information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring/exit pages, and the date and time of each visitor request, browser type, and operating system. Extole’s purpose in collecting non-personal information is to better understand how Extole’s visitors use its website. From time to time, Extole may release non-personal information in the aggregate, for example, by publishing a report on trends in the usage of its service.
Extole also collects potentially personal information like Internet Protocol (IP) addresses. Extole does not use such information to identify its visitors, however, and does not disclose such information, other than under the same circumstances that it uses and discloses personal information, as described below.
Collection and Use of Personal Information
We collect the following personal information from you when you visit our website:
- Contact Information such as name, email address, phone number
- Information about your business such as company name
As is true of most websites, we automatically gather information about your computer such as your IP address, browser type, referring/exit pages, and operating system. We use this information to
- Send you requested product or service information
- Enable you to post your resume, search job postings, and contact or be contacted by prospective employers
We do not link this automatically collected data to personally identifiable information.
We may also collect, from you, the following personal information about your contacts:
- Name and email address, in order to refer our products or services
When you provide us with personal information about your contacts we will only use this information for the specific reason for which it is provided.
If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at firstname.lastname@example.org.
In addition Extole provides the technology to promote referral-marketing campaigns for our clients. Extole enables certain users to participate in or promote referral-marketing campaigns for advertisers on the Extole network. Those users who would like to participate in an Extole campaign require Extole to know a little bit more about them, i.e., personal information. To participate in an Extole campaign, users must provide certain personal information, such as their name and email address. Extole does not disclose personal information other than as described below. And users can always refuse to supply personal information, with the caveat that it may prevent them from engaging in certain website-related activities (i.e. participating in an Extole campaign).
Extole also has functionality where we may collect some of your personal information through the Facebook Connect and the Graph API. Your data will be shared with us from Facebook. We use Facebook Connect or an Open ID provider to authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form and to post information about your activities on this Web site to your profile page to share with others within your network.
Extole will retain personal data we process on behalf of our Clients for as long as needed provide services to our Client. Extole will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We will share your personal information with third parties only in the ways that are described in this privacy statement. We do not sell your personal information to third parties. We may provide your personal information to companies that provide services to help us with our business activities:
- hosting company
These companies are authorized to use your personal information only as necessary to provide these services to us. We may also disclose your personal information
- as required by law such as to comply with a subpoena, or similar legal or bankruptcy process
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,
- 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,
- if Extole is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information,
- to any other third party with your prior consent to do so.
Extole, Inc. may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
Technologies such as: cookies, beacons, tags and scripts are used by Extole, Inc. and our partners including Google Analytics, Intercomm, Readme.io, and Zendesk. 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.
Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LS such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LS.
The security of your personal information is important to us. When you enter sensitive information (such as login credentials) we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our sites, you can contact us as described below.
Links to Other Sites
Our site contains links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information.
Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas might be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us as described below. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. This privacy statement applies only to information collected by this Web site and everywhere else it is posted.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. 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 email@example.com.
Social Media Widgets
Communications from Us
If you register for any of the Extole programs and applications, you may receive promotional communications on behalf of our client. You can opt out of these by unsubscribing through the unsubscribe link in the email.
Updating of Personal information, and Opt-Out
Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. Extole permits its visitors to freely update, correct or delete any personal information maintained by Extole. To do so, visitors need only look for the links and other tools available on Extole’s website or contact Extole by email. Visitors who no longer wish to receive materials distributed pursuant to an Extole mailing list should notify Extole by the same means.
Extole has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, who seeks to correct, amend, delete inaccurate data or withdraw consent to further contact should direct his/her query to the Extole’s Client (the data controller). We will respond to requests for access within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us as described below. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you would like the information we hold about you deleted, please contact us as described below. We will respond to your request within 30 business days, and delete your data within 60 business days.
Extole’s services are available only to, and may only be used by individuals who can form legally binding contracts under applicable law. Without limiting the foregoing, Extole’s services are not available to children (persons under the age of 18) or to temporarily or indefinitely suspended Extole members. If you do not qualify, please do not use Extole service. Further, your Extole account (including feedback) and User ID may not be transferred or sold to another third party.
Without limiting any other remedies, Extole may suspend or terminate your account if it suspects that you (by conviction, settlement, insurance or escrow investigation, or otherwise) have engaged in fraudulent activity in connection with the Extole service.
Your use of the Extole service to participate in certain Extole campaigns shall not: (a) be false, inaccurate or misleading; (b) be fraudulent or involve the sale of illegal services or items; (c) infringe any third party’s copyright, patent, trademark, trade secret or other proprietary rights or rights of publicity or privacy; (d) violate any applicable law, statute, professional code of conduct, ordinance or regulation (including, but not limited to restrictions on sharing of fees, restrictions on giving referral fees, consumer protection, unfair competition, anti-discrimination or false advertising); (e) be defamatory, trade libelous, unlawfully threatening or unlawfully harassing; (f) be obscene or contain child pornography; (g) contain any viruses, Trojan horses, worms, time bombs, cancelbots, easter eggs or other computer programming routines that may damage, detrimentally interfere with, surreptitiously intercept or expropriate any system, data or personal information; (h) create liability for us or cause us to lose (in whole or in part) the services of our ISPs or other suppliers; and (i) link directly or indirectly to or include descriptions of goods or services that are prohibited under this Agreement or ones that you do not have a right to link to or include.
Notification of Privacy Statement Changes
We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
You can contact us by writing at the address below:
350 Sansome Street, Suite 700
San Francisco, CA 94104
or email us at firstname.lastname@example.org