Effective Date: 7/17/2019
1. What Information Does Accordion Collect?
We do. Under the GDPR, Accordion is what is known as the “Controller” of the Personal Data that you provide to us. We collect information from you on the Service, and we are responsible for protection of your information.
2. What Information Does Accordion Collect?
A. Requested Information. During onboarding as a user of the Service, we may request specific PII about you in order to add you as a user, add you to our email list, facilitate your payments for Service, or fulfill your requests for services or information. You may choose not to provide your PII, but then you might not be able to take advantage of some of the features of our Service. We only collect basic personal data about you that does not include any special types of information (e.g., health-related) as defined in the GDPR. The types of personal information we collect and save include:
- Contact and account information, such as name, mailing address, email address, phone number, username, work history and work information, business name, business URL, location of business, and type of industry;
- Technical information, collected in our logs. Such information may include standard web log entries that contain your device identifiers and information, operating system information, clickstream data, IP address, previous page URL, referring page URL and timestamps;
- Employment information, such as the name of your employer, work history and work information, and your employer’s business name, URL, location and type of industry; and
- Location-based information.
B. Aggregate Information. We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, the type of operating system you are using, the date and time of any request, language preference, referring site, and the domain name of your Internet service provider.
C. Content. We may collect information that you upload or otherwise submit to the Service as Content so that you may take advantage of the workflow collaboration and content-sharing functionalities of the Service. We collect Content only if, and to the extent that, you upload it to the Service. Content shall only contain your PII to the extent that you, or another User authorized by you, include such PII in such Content.
3. Why Is My Information Being Collected?
We need to collect your personal information so that we can respond to your requests for information or to be added to our email lists, and to process your requests to access, and payment for, the Service. We also collect aggregate information to help us better design the Service. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide services to you. We collect Content for purposes of providing the Services, including the workflow collaboration and content-sharing functionalities of the Service, and to anonymize and use as described herein.
4. How Do We Use the Information We Collect?
A. We use the personal information you provide for the purposes for which you have submitted it including:
- Responding To Your Inquiries and Fulfilling Your Requests. We may use your PII to respond to your inquiries and to fulfill your requests for information.
- Creating and Maintaining Your User Account. We use your PII to create and maintain an account for you to allow you to purchase and use the Service.
- Subscribing to the Service. We may use your PII to add your subscriptions to our Service. * * Communicating With You About Our Services. We may use your PII to send you information about new services and other items that may be of interest to you.
B. We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Site is used, as well as to offer you programs or services.
C. We may use your Content to provide the workflow collaboration and content-functionalities of the Service, as directed by you. We may also anonymize your Content and use it for purposes of improving the design and content of our Service, analyzing how the Service is used, and performing analytics and benchmarking, and for general business purposes.
5. Do We Share Your Personal Information?
We will not share your personal information except: (a) for the purposes for which you provided it; (b) with your consent; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); or (d) with persons or organizations with whom we contract to carry out internal operations or business activities. With your knowledge and consent, we may share your personal information with our business partners. We may also share aggregate information with others, including affiliated and non-affiliated organizations. Finally, we may transfer your Personal Data to our successor-in-interest in the event of an acquisition, sale, merger or bankruptcy.
We may provide your payment information to a third party service provider for purposes of payment processing.
We may share your Content with other Users via the Service, as directed by you. We may use and share anonymized Content for purposes of improving the design and content of our Service, analyzing how the Service is used, performing analytics and benchmarking, and for general business purposes.
6. How Can You Access And Control Your Information?
After becoming a user of the Service, you may view, revise or edit certain personal information associated with you by logging into the Service, or by sending an email to firstname.lastname@example.org.
For instructions on how you can further access your personal information that we have collected, or how to correct errors in such information, please send an email to email@example.com. We will also promptly stop using your information and remove it from our servers and database at any time upon your e-mail request. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections or removing your information.
7. How We Store and Protect Your Information
A. After receiving your personal information, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers’ systems.
B. If you are accessing the Service from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA.
C. We store your personal information until you request us to remove it from our servers unless we have the legal authority to maintain that information. We store our logs and other technical records indefinitely.
A. To enhance your online experience with us, our web pages may presently or in the future use “cookies.” Cookies are text files that our web server may place on your hard disk to store your preferences. Cookies, by themselves, do not tell us your email address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Certain features of the Services may not function properly without the aid of cookies.
A.* Accordion or our service providers may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some Accordion Site pages and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of the Accordion Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.
B. As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data”, can be collected and stored by a website’s server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to the Accordion Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Site.
C. Do Not Track. At present, the Site does not specifically respond to browser do-not-track signals.
9. Collection of Information by Others
Our Terms of Service document identifies certain third party websites to which we may provide links, and that you may access through on our Site. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.
10. Data Subject Rights
If you are a data subject as defined under the GDPR, you have eight rights. These are:
A. The right to be informed. This is your right to be informed about what they are processing, why, and who else the data may be passed to.
B. The right of access. This is your right to see what data about you is held by us.
C. The right to rectification. This is the right to have your data corrected or amended if what is held is incorrect in some way.
D. The right to erasure. This is the right to have your personal data to be deleted in the event that such data is no longer required for the purposes it was collected for, your consent for the processing of the data is withdrawn, or the data is being unlawfully processed.
E. The right to restrict processing. This is the right to ask for a temporary halt to processing of your personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
F. The right to data portability. This is the right to ask for your personal data to be provided to you in a structured, commonly used, and machine-readable format.G. The right to object. This is the right to object to further processing your personal data if such processing is inconsistent with the primary purposes for which it was collected.
H. Rights in relation to automated decision making and profiling. This is the right to not be subject to a decision based solely on automated processing. The Service does not engage in automated decision making and profiling.
11. Children and Young People’s Information
We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the GDPR, USA Children’s Online Privacy Protection Act (“COPPA”) and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC’s website ( www.ftc.gov ) for more information. If you have concerns about this Site, wish to find out if your child has accessed our services, or wish to remove your child’s personal information from out servers, please contact us at firstname.lastname@example.org. Our Site will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at email@example.com.
12. California Privacy Rights
California law allows California residents to request information regarding our disclosures in the prior calendar year, if any, of their PII to third parties. To make such a request, please contact us at firstname.lastname@example.org with “Request for Privacy Information” in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.
13. Changes to this Policy
14. Our Contact Information
Copyright © 2019, ACCORDION TECHNOLOGIES LLC All rights reserved. The Site and Service are the property of Accordion, and is protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Site and Service, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.