Privacy Policy

Last Updated May 16, 2018

 

1. Introduction

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

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

For the purposes of this Policy, the term, “Websites” refers collectively to www.VisibleThread.com as well as the other websites that VisibleThread operates and that link to this Policy.


2. Scope Of This Policy

In this Policy, we define personal information as information relating to an identified or identifiable natural person.

An identifiable person is someone who can be identified with information such as a name, an identification number, location data, or an online identifier.

Our Websites may contain links to other websites. The information practices and the content of those other websites are governed by their own privacy statements. If you have any concerns, take the time to read their privacy statements.

Except for Account Information (as defined below) and other information we collect in connection with your registration or authentication into our Products and Services (as defined below), this Policy does not apply to our security and privacy practices in connection with your access to and use of our Products and Services.

These security and privacy practices, including how we protect, collect, and use electronic data, text, messages, communications or other materials submitted to and stored within our Products and Services by You (“Service Data”) are detailed in and governed by our Subscription Agreements (referred to as the “Subscription Agreement”).

Subscribers to our Services may upload documents or specify webpages for analysis. Or they may use our Services to analyze plain text.

If Subscribers upload documents or text that contains personal information, then Subscribers are solely responsible for the correct handling of that personal information.


3. How We Handle Information That You Provide To Us

Account and Registration Information:

We often ask for and collect personal information about you such as your name, address, phone number, email address, and credit card information, as well as certain related information like your company name and website name, when you register for an account to access or utilize one or more of our Products and Services (an “Account”).

We also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with Your Account.

If you sign-up for a free trial Account, you are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. A third-party intermediary is used to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.

We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you’re telling us that you are the owner of that personal data. Or you have permission by the owner to provide it to us.

Other Submissions:

We ask for and may collect personal information from you when you submit web forms on our Websites or 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 ask for and may collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which any member of VisibleThread participates.

Mobile Application:

When you download and use our Services, we automatically collect information on the type of device you use, and operating system version.


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 Web site can use to recognize a repeat visitor to the Web site. We use cookies for various reasons. Cookies enable us to provide you with a better experience by allowing us to understand what areas of this site are of interest to our users. These technologies may provide us with personal information, information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites.

Cookies from VisibleThread can only be read by VisibleThread website. If you do not want VisibleThread to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. If you choose to disable cookies in your browser, you can still access most of this site, however, your ability to use some of the products and/or services at this site may be affected.

Web beacons, tags and scripts may be used on our Websites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.

Logs:

As is true with most websites and services delivered over the Internet, 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 as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance 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 the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on our Websites. These features may collect your Internet protocol address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Websites. Your interactions with these features are governed by the privacy statement of the companies that provide them.

Information From Third Party Services:

We may also obtain other information, including personal information, from third parties and combine that with information we collect through our Websites. For example, we may have access to certain information from a third party social media or authentication service if you log into our Services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third party social media or authentication service is in accordance with the authorization procedures determined by that service. By authorizing 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 makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services. For example, you can log in to the Services using sign-in services such as Facebook Connect or an Open ID provider, as further described below.

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, provide you with the option to share certain personal information (such as your name and email address) with us, and pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities in the Services to your profile page to share with others within your network.


6. How We Use Information That 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 you related information, including purchase confirmations and invoices;
  4. send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
  5. send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and 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 or following 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 in connection with the Websites and Services and for marketing or advertising purposes;
  8. investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
  9. personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; and
  10. for other purposes for which we obtain your consent

 

Legal Basis for Processing (EEA only):

If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where:

  1. we have your consent to do so,
  2. where we need the personal information to perform a contract with you (e.g. to deliver VisibleThread Services you have requested), or
  3. where the processing is in our or a third party’s legitimate interests (and 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, or may otherwise need the personal information to protect your vital interests or those of another person.

 

Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time. And we will advise you whether the provision of your personal information is mandatory or not. We will also let you know the possible consequences if you do not provide your personal information.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at 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 that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:
In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order 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 choose to use our referral service to tell a friend about our products and services, we will ask you for your friend’s name and email address. We will automatically send your friend an email inviting him or her to visit the Websites and will store this information for the purpose of sending this initial email, tracking the success of our referral program and other marketing activities. Your referral may contact us at info@VisibleThread.com to request that we remove his/her information from our database.

Community Forums:

The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your personal information from an Interactive Area, contact us at info@VisibleThread.com. 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.

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 primarily store personal information about Website Visitors and Subscribers within the European Economic Area (the “EEA”), the United States and in other countries and territories. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which we have operations.

If you are visiting our Websites from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.

If you are visiting our Websites from the EEA or other regions with laws governing data collection and use, please note that by providing this personal information, you acknowledge that your personal information may be transferred to the United States and other jurisdictions in which we operate.


9. Communications Preferences

We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non- transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request to info@VisibleThread.com.


10. How Long We Retain Your Personal Information

We will retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


11. Your Privacy Rights

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. 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 or by contacting 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 Territories:

If you are from certain territories (such as the EEA), you may have the right to exercise additional rights available to you under applicable laws, including:

  • 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 in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
  • Right to object to processing: You may have the right to request that VisibleThread stop processing your personal information and/or to stop sending you 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 inaccurate or unlawfully held).
  • Right to data portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to 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 also have the right to complain to a data protection authority about our collection and use of your personal 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 do not submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through the Websites or Services, please contact us at info@VisibleThread.com, and we will use commercially reasonable efforts to delete that information.


13. Business Transactions

We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.


14. Supplemental Terms and Conditions for Certain Regions

Brazil:

Personal information collected, stored, used and/or processed by VisibleThread, as described in this Policy, is collected, stored, used and/or processed in accordance with Brazilian Law No. 12,965/2014. Those individuals who use or access our Website or Services expressly consent to the collection, use, storage and processing of their personal information by us for the purposes described in this Policy.

Australia:

Personal information collected, stored, used and/or processed by VisibleThread, as described in this Policy, is collected, stored, used and/or processed in compliance with the Australian Privacy Act 1988 (Commonwealth).

If you are dissatisfied with our handling of a complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office of the Australian Information Commissioner (“OAIC”) by contacting 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, as described in this Policy, is collected, stored, used and/or processed in compliance with New Zealand’s Privacy Act 1993 and its 12 Information Privacy Principles (“NZ IPPs”).

Singapore:

Personal information collected, stored, used and/or processed by VisibleThread, as described in this Policy, is collected, stored, used and/or processed in compliance with VisibleThread’s obligations under the Personal Data Protection Act 2012 of Singapore (“PDPA”).

Canada:

Personal information (as the term is defined in the Personal Information Protection and Electronic Documents Act of Canada (“PIPEDA”)) will be collected, stored, used and/or processed by VisibleThread in compliance with VisibleThread’s obligations under PIPEDA.


15. Changes To This Policy

If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Websites or the Services constitutes your agreement to be bound by such changes to this Policy. If you do not accept the terms of this Policy, you should discontinue use of the Websites and the 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.