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Privacy Policy
Privacy Policy (Last Updated January 21,
2021)
Welcome
to the EasyManage Privacy Policy (“Privacy Policy” or
“Policy”). We take the privacy and security of your
information seriously, and work hard to maintain secure websites and
services for your use. EasyManage.com
and FeedsInfo.com, FeedsHealth.com, FeedsLearning.com
and its affiliates (“we”, “us”,
“EasyManage”, “our” or the “Company”)
are committed to protecting your privacy.
This Privacy Policy
(together with Master Subscription Agreement terms, Terms of Use and
other documents referred to herein) sets out the basis on which any
Personal Data (as defined below) we collect from you, or that you
provide to us, will be processed by the Company. It also covers
processing of employee personal information by the Company and
personal information the Company receives from its customers and
suppliers. By visiting the Company websites,
including www.EasyManage.com,
FeedsInfo.com, FeedsHealth.com, FeedsLearning.com,
hereinafter referred to as “the Site(s),” or by
subscribing or purchasing our Services, you accept the privacy
statements described in this Policy. For example, when you fill out
and submit a registration form, and/or download a specific piece of
content, we will receive your contact information. If you have
questions or complaints regarding this Privacy Policy, please
contact us at: info@EasyManage.com.
Purpose: This Privacy Policy is
intended to help you better understand our practices regarding
information collected, including through (i) the Sites, (ii) any of
our products and services offered through the Sites and (iii) any
other digital properties that we own or control (collectively, the
“EasyManage Services” or “Services”). This
Privacy Policy describes how EasyManage collects, processes, shares
and retains the personal information (or, in the EU/Switzerland,
“personal data”) you provide to us through the
EasyManage Services.
Scope: This Policy applies whether
you are a customer that uses the EasyManage Services, a prospective
customer, an end user of our customers’ services that utilize
our solutions, a prospective employee, partner, supplier,
independent contractor, or whether you are simply visiting our Sites
(each a “User” or “you,” and collectively,
“Users”).
Consent: When you interact with the
EasyManage Services, you consent to the collection, processing,
sharing and retaining of information (including personal
information/personal data) as described in this Privacy Policy and
all additional terms and conditions, including but not limited to
all applicable Master Subscription Agreement terms,
(incorporated herein by reference) governing your use of the
EasyManage Services. You are also responsible for ensuring that the
entity or people on behalf of which you are acting (such as your
employer) are aware of the content of this Privacy Policy and that
you have confirmed that they agree to the terms of this Privacy
Policy.
IF YOU DO NOT CONSENT TO THE TERMS OF THIS
PRIVACY POLICY, THE TERMS OF USE AND ALL ADDITIONAL TERMS AND
CONDITIONS, DO NOT CONTINUE TO INTERACT WITH OR USE THE EASYMANAGE
SERVICES.
European Privacy Policy: Please also
see our European Privacy Policy for further information on
your rights under applicable European privacy law.
CONTENTS:
GENERAL PRIVACY POLICY
Information We May Collect
Use of Information
Sharing of Information
Cookies and Similar Technologies
Data Retention
Choices and Opt-Out
Cross-Device Tracking
Employment Opportunities
Third-Party Sites
Security
Children
Sensitive Personal Information
International Data Transfers
California Privacy Rights
Questions, Complaints and Disputes
Privacy Policy Updates
European Privacy Policy
Contact Information
A.
GENERAL PRIVACY POLICY
1.
INFORMATION WE MAY COLLECT
We
only collect personal information for the purposes of conducting
our business, including in relation to providing the EasyManage
Services. We collect, process, share, and retain information from
you and any devices you may use when you access our Sites, register
for an event or account with us, provide us information on a web
form, update or add information to your account, participate in
chats, or otherwise correspond with us.
The
type of personal information we collect depends on your use of the
EasyManage Services and/or your relationship with us (for example,
whether you are a customer, prospective employee, etc.). Examples
of the types of information we collect are:
Your first and last names and contact
details, including residential address, telephone number, and
email address
Payment or financial information for
billing purposes (credit card details)
Your passwords and/or personal
identification codes (PINs)
Employer or organizational affiliation
for a User of the EasyManage Services
IP address or MAC address, and
information derived from an IP or MAC address, such as geographic
location
Referring domain, destination domain and
destination path
Geolocation data
User IDs and passwords for Users with
accounts on the EasyManage Services
Employee data regarding current position
and employment history
Your testimonials, feedback and
complaints
Browsing activities, cookies and similar
data, and platform or mobile application use data
Screen name
Screen sharing views, at the request of
Users, for support and quality assurance (“QA”)
purposes
Any data in any files uploaded, emailed
or otherwise provided by Users for support and QA
Operating system type and version, web
server type and version, database type and version
Unique IDs such as a cookie placed on a
computer or mobile device, or device IDs
Information about the performance,
security, software configuration and availability of our software
on your servers and network
Statistics regarding use of the Sites
and viewing activity records
Communication preferences
Other similar information
We
may collect your personal information in several ways, including,
in person, by telephone, by email or electronically when you
contact us, visit our Sites or use our Services, including as
follows:
Registration, purchase and use of the
EasyManage Services: Information such as name, email address,
telephone number, company/organization, and other information, may
be collected in connection with registration for, or purchase or
use of, the EasyManage Services (for example, to sign-up for and
log into the EasyManage Services and/or register for an event).
Users may update their information by logging into their account.
Communications: Personal
information such as name, email address, and other information,
may be collected, when provided in any communications, whether via
email, social media, telephone or otherwise.
Support: Personal information may
be collected in connection with User support, whether via
screensharing, email, social media, telephone or otherwise.
Information We Automatically Collect: We
receive and store certain types of information whenever you
interact with us or our Sites. Our Sites use “cookies,”
tagging and other tracking technologies. This information includes
computer and connection information such as statistics on your
page views, traffic to and from our Sites, referral URL, ad data,
your IP address, and device identifiers; this information may also
include your browsing history, transaction history, and your web
log information.
Sign-in Features: Our Sites may
include links to other websites and online services whose privacy
practices may differ from those of EasyManage. These services will
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. If you submit personal
information to or through any of those websites or services, your
information is governed by the privacy policies of such
third-party sites or services. We encourage you to carefully read
the privacy statement of any website you visit or online services
you use.
User Comments and Content: If you
post any comments or content on our Sites, you should be aware
that any personal information you choose to provide there may be
read, collected, or used by third-parties. We are not responsible
for the information you choose to submit, and we cannot guarantee
that third-parties have not made copies of, or will not use, such
information in any way. No protected health information or
sensitive personal information (in each case, as defined in
Section 12, below) should be provided to us through the EasyManage
Services.
Information from Other Sources: We
may supplement the personal information we collect with
information from third-parties, including to add it to your
account information. Information from third-parties may include,
but is not limited to, demographic information that is publicly
available, additional contact information, group affiliations,
occupational information, and educational background. We may also
collect your personal information from third-parties, including
data available on the internet, and data purchased from
third-party sources. Where personal information is obtained from
third-party sources, the collection, use and disclosure of that
personal information will be governed by the third-party's privacy
policy, as well as by applicable privacy laws. If you are a
prospective employee, we may also collect personal information
from credit agencies (after seeking your consent to do so).
You
can choose not to provide us with certain information, in which
case you might not be able to take advantage of certain features
of the EasyManage Services and EasyManage may not be able to
provide you with certain Services.
2. USE
OF INFORMATION
We may use the information, including
personal information, collected in connection with the Sites or for
providing the EasyManage Services to you, as well as for supporting
our business functions, such as fraud prevention, marketing,
analytics and legal functions, and other legitimate purposes.
To the extent permitted by applicable law
and, for customer data, as permitted by our customer agreements,
including but not limited to all applicable Master Subscription
Agreements, we may use information collected in connection with the
Sites and our Services:
to deliver certain of our Services from
our Sites;
to provide, maintain, and improve the
Sites for internal or other business purposes;
to fulfill User requests, such as to
create a EasyManage Services account or to provide requested
Services;
to communicate with our Users; to inform
Users, as applicable, of products, programs, services profiles or
transactions with us, and changes to our policies or terms, as
applicable;
to send offers, promotions, or other
communications about our Services, including special or
promotional events, including services, products, or events for
which we collaborate or co-offer with a third-party;
to send Users information regarding the
EasyManage Services, including information about features and
enhancements on or to our Sites and issues specifically affecting
our Services;
to respond to reviews, comments, or
other feedback provided to us;
to support, optimize, improve and
personalize our Services, Sites, mobile services, and advertising,
including tracking and evaluating the use of the Sites;
to send newsletters or other materials;
to populate online profiles of Users;
to protect the security and integrity of
our Services, content, and our business;
for marketing purposes and to explore
prospective sales leads;
to check financial qualifications and
collect payments;
for benchmarking, data analysis, audits,
developing new products, enhancing our Services, facilitating
product, software and applications development, improving our
Services, conducting research, analysis, studies or surveys,
identifying usage trends, as well as for other analytics purposes;
in the case of server logs, to help us
statistically monitor how many people are using our Site and for
what purpose;
to perform statistical, demographic, and
marketing analyses of Users of the Sites and their viewing
patterns;
to meet our contractual requirements, to
comply with applicable legal or regulatory requirements and our
policies, and to protect against criminal activity, claims and
other liabilities; and/or
for any other lawful purpose for which
the information is provided, including fulfilling requests for
information.
Personal information under the control of
Users of the EasyManage Services. In some circumstances, we
may access and use personal information that has been collected by
a User in the course of their use of the EasyManage Services. This
personal information remains under the control of the User at all
times. We will only use this information on a limited basis to:
diagnose and address software issues;
provide hosting services;
fulfill IT-related duties for technical
maintenance and the backup of the hosting environment;
provide services in relation to the
installation and configuration of our software;
assist with the preparation and
migration of data to our software;
develop product enhancements; and/or
provide data capturing services.
Customer Data Uploaded to EasyManage
Services. The Company does not own, control or direct the use
of any of the EasyManage customer data stored or processed by a
customer via the Services. Only the customer is entitled to access,
retrieve and direct the use of such customer data. The Company does
not directly access or control such customer data except as
authorized by the customer, or as necessary to provide Services to
the customer.
Because the Company does not determine
the use of any data contained in the customer data and because it
does not determine the purposes for which such customer data is
collected, the means of collecting such customer data, or the uses
of such customer data, the Company is not acting in the capacity of
data controller pursuant to the terms of the European Union’s
General Data Protection Regulation (Regulation (EU) 2016/679,
hereinafter “GDPR”) and does not have the associated
data controller’s responsibilities under the GDPR. The
Company should be considered only as a “processor” (as
defined in the GDPR) on behalf of its customers as to any customer
data containing personal data that is subject to the requirements
of the GDPR. Except as provided in this Privacy Policy, the Company
does not independently cause customer data stored in connection
with the Services to be transferred or otherwise made available to
third parties, except to third party subcontractors who may process
such data on behalf of the Company in connection with the Company’s
provision of Services to customers. Such actions are performed or
authorized only by the applicable customer.
The customer is the data controller under
the GDPR for any customer data, including that which contains
personal data, meaning that such party controls how such personal
data is collected and used, as well as the determination of the
purposes and means of the processing of such personal data.
The Company is responsible for neither
the content of the personal data contained in the customer data or
other information stored on its servers (or its subcontractors’
servers) at the discretion of the customer, nor for the manner in
which the customer collects, handles disclosures of, distributes or
otherwise processes such information.
Aggregate Information. To the extent
permitted by applicable law, we may use, process, transfer, and
store any data about Users in an anonymous (or pseudonymous) and
aggregated manner. We may combine personal information with other
information, collected online and offline, including information
from third-party sources. We may also use information in other ways
with consent or as permitted by
applicable law. By using the Sites, our Users agree that we are
licensed to collect, use, share and store anonymized (or
pseudonymized) aggregated data collected through the EasyManage
Services for benchmarking, analytics, A/B testing, metrics,
research, reporting, machine learning and other business purposes.
Automated Decisions. To the extent
permitted by applicable law, we may collect data in an automated
manner and make automated decisions, including using machine
learning algorithms, about individual Users of the EasyManage
Services to provide or optimize the EasyManage Services offered
and/or delivered, for security or analytics purposes, and for any
other lawful purpose.
3.
SHARING OF INFORMATION
To the extent permitted by applicable
law, we may share and disclose information, including personal
information, as set forth below:
Customers. We may share information
with our customers and their service providers and other platforms
that may assist those customers.
Affiliates and Agents. We may share
information with our affiliates, any business partners or agents
acting on our behalf. Please refer to the websites of such
third-party suppliers for their Privacy Policies and other
information on such supplier.
Online e-commerce: When you
transact through the Sites, you may interact with third-party
providers that host online e-commerce platforms that allow us to
sell and bill those Services to you. Your data may be stored on
such third-parties’ data storage, databases and general
application(s) platform(s).
Service Providers. We may share
information with our service providers (e.g., data storage service
providers), agents, vendors and other third-parties we use to
support and advertise the EasyManage Services and our business. We
share personal information with such third-parties to the extent
necessary to provide services to us, and pursuant to binding
contractual obligations.
Advertising and Marketing. To the
extent permitted by applicable law, we may share information with
third-parties for marketing, advertising, promotions, contests, or
other similar purposes. If required by applicable law,
we will share such data for advertising and marketing purposes
only in an aggregate, anonymous, and de-identified manner.
Non-personally identifiable
information. We may make certain automatically collected,
aggregated, or otherwise non-personally-identifiable information
available to third parties for various purposes, including, for
example, compliance with various reporting obligations; for
business or marketing purposes; and/or to assist such parties in
understanding User interests, habits, and usage patterns for
certain programs, content, services, and/or functionality
available through the Services.
Mergers, Acquisitions, Divestitures. We
may share, disclose or transfer information to a buyer, investor,
new affiliate, or other successor in the event EasyManage, or any
affiliate, portion, group or business unit thereof, undergoes a
business transition, such as a merger, acquisition, joint venture,
consolidation, reorganization, divestiture, liquidation or
dissolution (including bankruptcy), or a sale or other transfer of
all or a portion of any assets of EasyManage or any affiliates or
during steps in contemplation of such activities (e.g.,
negotiations and due diligence).
Law Enforcement and National
Security. We may share information with legal, governmental,
or judicial authorities, as instructed or required by those
authorities or applicable laws, or to comply with any law or
directive, judicial or administrative order, legal process or
investigation, warrant, subpoena, government request, regulatory
request, law enforcement or national security investigation, or as
otherwise required or authorized by law.
Protection of Rights, Property or
Safety. We may also share information if, in our sole
discretion, we believe disclosure is necessary or appropriate to
protect the rights, property or safety of any person, or if we
suspect fraud or other illegal activity,
We may also disclose personal information
for other purposes or to other third-parties when a User has
consented to, or requested, such disclosure, or where a User has
obtained permission from another individual, or where such
disclosure is otherwise legally permitted for legitimate business
purposes and, for customer data, with such customer’s
authorization or otherwise in accordance with our agreement with
such customer.
4.
COOKIES AND SIMILAR TECHNOLOGIES
We may use cookies and tracking and
similar technologies to operate and improve the EasyManage
Services, as well as to simplify our interaction with you. A
"cookie" is a unique numeric code that we transfer to
your computer so that we can keep track of your interests and/or
preferences and recognize you as a return visitor to the EasyManage
Services. We may use cookies, log files, pixel tags, web bugs, web
beacons, clear GIFs, Local Storage Objects (LSOs) such as HTML5 and
Flash or other similar technologies to collect information about
the ways you interact with and use the EasyManage Services, to
support and enhance features and functionality, to monitor
performance, to personalize content and experiences, for marketing
and analytics, and for other lawful purposes. This may include
first-party cookies placed by EasyManage, and third-party cookies
placed by a website other than EasyManage, local shared objects
(commonly referred to as “Flash Cookies” or “HTML
5 Cookies”) and tracking pixels (including transparent or
clear gifs).
We may use session cookies and persistent
cookies in connection with the Sites or for providing the
EasyManage Services to you. Session cookies refer to cookies that
are operable for the duration of your visit only and are deleted
when you close your browser. Session cookies are typically used to
track your navigation of the Sites in order to support the function
or security of the Sites. Session cookies may also be used to avoid
data re-entry such as information you might provide within forms
available on the Sites. Persistent cookies refer to cookies that
are stored following your visit. Persistent cookies are not deleted
from your browser at the end of a session and are typically used to
remember your preferences for future visits and/or to provide
targeted advertising based on your activities on the Sites.
These cookies make websites easier to use
as you won’t need to repeatedly select your preferences each
time you visit. A good example would be a website with language
settings – perhaps you choose to change the content language
from English to French. The next time you visit the website, your
preference will be remembered.
We may use the following types of cookies
and similar technologies:
Essential/strictly necessary
cookies required for the operation of the EasyManage
Services. They include, for example, cookies that enable you to
log into secure areas. Strictly necessary cookies facilitate the
operation of our websites. Without the use of these cookies,
portions of our websites will not function properly.
Analytical/performance cookies that
collect information about how you use the EasyManage Services.
They allow us to recognize and count the number of visitors and to
see how visitors move around our Sites. This helps us to improve
the way our Sites work. These cookies are sometimes placed by
third-party providers of web traffic analysis services.
Functional cookies that remember
choices you make and recognize you when you return. This enables
us to personalize our content, greet you by name and remember your
preferences (for example, your choice of language or region) or
allow the pre-population of certain resource request forms, making
it easier for you to access EasyManage content.
Targeting cookies that collect
information about your browsing habits such as the pages you have
visited and the links you have followed. We use this information
to make our Sites more relevant to your interests, and, if we
enable advertising, to make advertising more relevant to you, as
well as to limit the number of times you see an ad. These cookies
are usually placed by third-party advertising networks. They
remember the other websites that you visit, and this information
is shared with third-party organizations, for example,
advertisers.
Opting out: Most internet browsers
accept cookies by default. You can block cookies by activating the
setting on your browser that allows you to reject all or some
cookies. The help and support area on your internet browser should
have instructions on how to block or delete cookies. Some web
browsers (including some mobile web browsers) provide settings that
allow you to control or reject cookies or to alert you to when a
cookie is placed on your computer, tablet or mobile device.
Although you are not required to accept cookies, if you block or
reject them, you may encounter issues using the Sites and accessing
certain pages, specifically password-protected pages.
As part of improving the EasyManage
Services, we may deploy third-party technology on our Sites to
collect and transfer information using web
beacons, and in certain configurations, using tracking tag pixels
and cookies (“Tag Data”). This third-party technology
may automatically collect Tag Data from your browser. Some of the
Tag Data collected may be considered personal data in your
jurisdiction, such as IP address and online identifiers (cookies)
and some may be considered non-personal information, such as
browser version, operating system, pages viewed, and timestamps.
We may use third-party analytics such as
Google Analytics or similar analytics services. For information on
how Google processes and collects your information regarding
Google Analytics and how you can opt-out, please
see https://tools.google.com/dlpage/gaoptout.
Please note that the use of online
tracking mechanisms by third parties, such as our Partners, is
subject to those third parties’ own privacy policies, and
not this Privacy Policy. You may remove yourself from the targeted
advertising of companies within the Network Advertising Initiative
by opting out at: (https://optout.networkadvertising.org/) or of
companies participating in the Digital Advertising Alliance
program by opting out at: (https://optout.aboutads.info), the
Digital Advertising Alliance of Canada (DAAC) (for Canadian users)
by opting out at: (https://youradchoices.ca); or the European
Interactive Digital Advertising Alliance (EDAA) (for users in the
EU) by opting out at: (https://www.youronlinechoices.com).
5.
DATA RETENTION
To the extent permitted by applicable
law, we may retain information for as long as the account of the
User for whom we collected the information is active, for at least
six (6) months thereafter, or as long as is reasonably necessary to
provide the EasyManage Services or as needed for other lawful
purposes. If, however, we become aware that you inadvertently or
intentionally submitted or transmitted Protected Health Information
or sensitive personal information to us, you will be considered to
have explicitly consented to us processing that Protected Health
Information or sensitive personal information for the purposes of
deleting the same and we will not retain such information. We may
retain cached or archived copies of information. We may retain
anonymized or pseudonymized, aggregated data indefinitely, to the
extent permitted under applicable law. We may be required to retain
some data for a longer period of time because of various laws and
regulations or because of contractual obligations. We also will
retain information as long as
reasonably necessary to comply with our legal obligations, resolve
disputes and enforce our agreements. Once information is no longer
needed for the purposes for which it was collected, we will take
reasonable steps to de-identify and/or destroy it.
6.
CHOICES AND OPT-OUT
To the extent required by applicable law,
or otherwise in our discretion, we will allow Users to limit use of
personal information. If at any time after providing us with your
personal information such information changes or you change your
mind about receiving information from us, you may request access to
your data or that your data be changed.
To the extent required by applicable law,
or otherwise in our discretion, we will allow Users to limit use of
personal information. If at any time after providing us with your
personal information such information changes or you change your
mind about receiving information from us, you may request access to
your data or that your data be changed.
Where you provide us with your personal
information (e.g. when you contact us to obtain information about a
EasyManage product or service), we may use your personal
information for direct marketing. This includes the use of personal
information to:
invite you to a user conference; and/or
notify you about an existing or new
product or service.
If you prefer not to receive these
communications from us, you may ask us at any time to stop sending
you direct marketing information or to stop being contacted by us.
You can do this by emailing us at: info@EasyManage.com.
7.
CROSS-DEVICE TRACKING
When you use your mobile device to
interact with us or use the EasyManage Services, we may receive
information about your mobile device, including a unique identifier
for your device. We and our service providers and third-parties we
collaborate with, including ad networks, may use
cross-device/cross-context tracking. For example, you might use
multiple browsers on a single device, or use various devices (such
as desktops, smartphones, and tablets), which can result
in your having multiple accounts or profiles across these various
contexts and devices. Cross-device/cross-context technology may be
used to connect these various accounts or profiles and the
corresponding data from the different contexts and devices.
8.
EMPLOYMENT OPPORTUNITIES
We provide you with a means for
submitting your resume or other personal information through our
Sites and/or Services for consideration for employment
opportunities at EasyManage. Personal information received through
resume submissions will be kept confidential. We may contact you
for additional information to supplement your resume, and we may
use your personal information within EasyManage, or keep it on file
for future use, as we make our hiring decisions.
9.
THIRD PARTY SITES
The EasyManage Services may provide links
to other websites or resources over which EasyManage does not have
control (“External Web Sites”). Such links do not
constitute an endorsement by EasyManage of those External Web
Sites. You acknowledge that EasyManage is providing these links to
you only as a convenience, and further agree that EasyManage is not
responsible for the content of such External Web Sites. Your use of
External Web Sites is subject to the terms of use and privacy
policies located on the applicable External Web Site. We encourage
you to be aware when leaving our Services and to read the privacy
statements of External Web Sites that collect your personal
information.
10.
SECURITY
To prevent unauthorized access or
disclosure, to maintain data accuracy, and to ensure the
appropriate use of personal information, we employ administrative,
technical and organizational measures that are reasonably designed
to help safeguard the information we collect. Only authorized
EasyManage personnel have access to the personal information,
including server logs and cookie utilization data, that we collect.
These individuals are required to follow strict security policies
and procedures. EasyManage may use data encryption, network channel
encryption, firewall, malware and threat protection, access
protection controls, and other physical and logical security
measures to help prevent unauthorized access to such personal
information. EasyManage may also place internal
restrictions on who in the Company may access data to help prevent
unauthorized access to such information.
Unfortunately, no data transmission over
the Internet or data storage system can be guaranteed to be 100%
secure. Therefore, despite our efforts, we cannot guarantee its
absolute security. We do not warrant or represent that personal
information about you will be protected against loss, misuse, or
alteration by third-parties.
If you use the EasyManage Services, you
are responsible for maintaining the confidentiality of your access
information and password. You are responsible for restricting
access to your computer, and you agree to accept responsibility for
all activities that occur under your password. We cannot secure any
personal information that you release on your own, that you request
us to release or that is released through another third party to
whom you’ve given access.
Where required under applicable law or by
contract, we will notify the appropriate parties or individuals of
any loss, misuse or alteration of personal information so that such
parties or individuals can take the appropriate actions for the due
protection of their rights. If such personal information is
information of a EasyManage customer, we will notify such customer
and coordinate with them regarding any required notices to
particular individuals.
11.
CHILDREN
We recognize the importance of protecting
the privacy and safety of children. The EasyManage Services are not
intended for children under 13 years of age - and for European
residents, for children under 16 years of age - see our European
Privacy Policy. We do not knowingly collect personal information
from children under 13. Anyone under 13 should not use the
EasyManage Services. If we learn we have collected or received
personal information from a child under 13 without verification of
parental consent, we will delete that information. If you believe
we might have any information from or about a child under 13,
please contact us as set forth below.
12.
SENSITIVE PERSONAL INFORMATION
“Sensitive personal information”
is information about an individual that reveals their racial or
ethnic origin, political opinions, religious or philosophical
beliefs, or trade union membership, genetic information, biometric
information for the purpose of uniquely identifying an individual,
information concerning health or information concerning a natural
person’s sex life or sexual orientation.
We do not knowingly or intentionally
collect sensitive personal information or Protected Health
Information (as defined under the Health Insurance Portability and
Accountability Act of 1996 (HIPAA) and summarized by the U.S.
Department of Health & Human Services
here: https://www.hhs.gov/hipaa/for-professionals/privacy/laws-regulations/index.html )
from individuals through the EasyManage Services. You must not
submit to us sensitive personal information or protected health
information of any kind through the EasyManage Services. If,
however, you inadvertently or intentionally submit or transmit
sensitive personal information and/or protected health information
to us, you will be considered to have explicitly consented to us
processing that information. In such case, we will use and process
protected health information and sensitive personal information
solely for the purposes of deleting it, if and when we become aware
of the same.
13.
INTERNATIONAL DATA TRANSFERS
The Sites may be provided using resources
and servers located in various countries around the world,
including the United States and other countries. Therefore,
personal information about Users may be transferred, processed and
stored outside the country where the EasyManage Services are used,
including to countries outside the European Union (“EU”),
European Economic Area (“EEA”) or Switzerland, where
the level of data protection may not be deemed adequate by the
European Commission. With respect to Europe, we may use standard
data protection clauses adopted by supervisory authorities and
approved by the European Commission to safeguard transfers.
14.
CALIFORNIA PRIVACY RIGHTS
California residents should read
our California Supplemental Privacy Notice in conjunction
with this Privacy Policy. The California Supplemental Privacy
Notice for California residents explains EasyManage’s
commitment to comply with California law and applies to personal
information of California residents collected in connection with
the Sites and the Services.
15.
QUESTIONS, COMPLAINTS AND DISPUTES
If you have questions, concerns, or
complaints about this Policy or our privacy practices, please
contact our Privacy Officer by email at info@EasyManage.com. We
will respond to your inquiries as soon as is practicable.
CLASS ACTION WAIVER. YOU AND WE AGREE
THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR OUR
INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY
PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.
DISPUTE RESOLUTION. Except as otherwise
expressly provided above, or in our European Privacy Policy or
otherwise required by applicable law, you agree that the exclusive
jurisdiction of any actions arising out of, relating to, or in any
way connected with, this Privacy Policy, shall be in the courts
located in Delaware, United States. Any dispute, controversy, or
claim arising out of or relating to this Privacy Policy or the
collection, use, storage or transfer of any of your information or
data, including, but not limited to, the arbitrability of the
matter or the formation, interpretation, scope, applicability,
termination, or breach of this Privacy Policy, shall be referred
to and finally determined by arbitration in accordance with the
JAMS Streamlined Arbitration Rules and Procedures, or JAMS
International Arbitration Rules, if the matter is deemed
"international" within the meaning of that term as
defined in the JAMS International Arbitration Rules. The
arbitration shall be administered by JAMS, shall take place before
a sole arbitrator, and shall be conducted in Dallas, Texas. If the
JAMS International Arbitration Rules apply, the language to be
used in the arbitral proceedings will be English. Judgment upon
the arbitral award may be entered by any court having
jurisdiction. This section shall apply to and require arbitration
of all disputes, controversies, and claims, regardless of whether
such disputes, controversies, or claims concern a single
individual, entity, or other person, multiple individuals,
entities, or other people, or classes of individuals, entities, or
other people. You hereby consent to receive service of process by
electronic means or social media to the extent allowed by the
applicable court. This constitutes express agreement of the
parties regarding your consent pursuant
to United States Federal Rule of Civil Procedure 5(b)(2)(E) and
any applicable state (or other jurisdiction) equivalent.
16.
PRIVACY POLICY UPDATES
We may update this Privacy Policy from
time to time in our sole discretion to reflect changes to our
information and privacy practices. We will post any updated Privacy
Policy on this page at https://www.EasyManage.com/ems/privacy.html
or in the EasyManage Services, or with any notice to individual
Users if required by applicable law. Continued use of the
EasyManage Services after any such modifications constitutes
acceptance to any such modified Privacy Policy. EasyManage
encourages you to review this Privacy Policy regularly for any
changes. The date of last revision is shown at the “Last
Updated” legend at the top of this page.
If you have any questions regarding our
Privacy Policy, the practices of this site, or your dealings with
us, please feel free to email us at info@EasyManage.com.
B.
EUROPEAN PRIVACY POLICY
The following European Privacy Policy
applies if your personal data is processed in the European Union,
the European Economic Area and/or Switzerland.
Personal Data and Processing. For
the purposes of this European Privacy Policy:
“Personal Data” means
any information relating to an identified or identifiable natural
person who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to
one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of such
natural person; and
“Processing” means
any operation or set of operations which is performed on Personal
Data or on sets of Personal Data, whether or not by automated
means, such as collection, recording, organization, structuring,
storage, adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise making
available, alignment or combination, restriction, erasure or
destruction.
Personal Data may be transferred outside
of Europe, provided that certain conditions as set out in the
applicable legislation are complied with. Your Personal Data will
also be processed by personnel operating outside Europe who work
for us. This includes personnel engaged in, among other things, the
fulfilment of your order and the provision of support services. We
are party to data transfer agreements with each of our service
providers and the members of our group and we will (i) keep each
document up to date with current law, and (ii) only engage in
personally identifiable information transfers from Europe to
outside Europe in accordance with such an agreement or an
alternative means of transfer in compliance with data protection
legislation. We may also process personal data submitted relating
to individuals in Europe via other compliance mechanisms, including
use of the European Union Standard Contractual Clauses.
Purposes and Legal Basis for Processing
Personal Data. We process data for the purposes as set forth
in our Privacy Policy, including to provide the EasyManage Services
and, as explained in the Use of Information and Sharing
of Information sections. To fulfill these purposes, we may
access data, including Personal Data, to provide the EasyManage
Services, to correct and address technical, service or security
problems, or in response to contractual requirements. Please see
our EasyManage Privacy Policy Information We Collect and Data
Retention sections for additional details on how we collect,
use, disclose and share data, make automated decisions, and retain
data, including Personal Data, about individual Users.
Our legal basis for the processing of
Personal Data are: (i) consent or (ii) any other applicable legal
basis, such as our legitimate interest in engaging in commerce,
offering products and services of value to the customers of the
EasyManage Services, preventing fraud, ensuring information and
network security, direct marketing and advertising, and complying
with industry practices.
Data Transfers:
Where personal data is transferred from
the EU or Switzerland to the US in the context of an employment
relationship, we will cooperate in investigations by and comply
with the advice of EU data protection agencies and the Swiss
Federal Data Protection and
Information Commissioner (FDPIC).
The Services may be provided using
resources and servers located in various countries around the
world, including the United States and other countries. Therefore,
personal information about individuals or customers may be
transferred, processed and stored outside the country where the
Services are used, including to countries outside the European
Union (“EU”), European Economic Area (“EEA”)
or Switzerland, where the level of data protection may not be
deemed adequate by the European Commission. In the case of such
transfers, EasyManage will rely upon a compliant transfer
mechanism, such as standard contractual clauses. We will only
transfer data to our agents, resellers or third-party service
providers (such as travel service providers, accountants,
attorneys, consultants, and other service providers) who need the
information in order to provide services to or perform activities
on behalf of EasyManage, including in connection with the delivery
of Services or products, EasyManage’s management,
administration, or legal responsibilities.
Additional Rights: Under European
law, you may have one or more of the following additional rights:
Access. To
request a copy of the Personal Data we have collected about you by
contacting us.
Rectification & Erasure. To
request that we rectify or delete any of the Personal Data about
you that is incomplete, incorrect, unnecessary or outdated.
Objection. To
object, at any time, to Personal Data about you being Processed
for direct marketing purposes.
Restriction of Processing. To
request restriction of Processing of Personal Data about you for
certain reasons, such as, for example, if you consider Personal
Data about you collected by us to be inaccurate or you have
objected to the Processing and the existence of legitimate grounds
for Processing is still under consideration.
Data Portability. To
request and receive the Personal Data we have collected about you
in a commonly used and machine-readable form.
Right to Withdraw Consent. If
Personal Data about you is processed solely based on your consent
and not for any other legitimate interest, to withdraw your
consent at any time, without affecting the lawfulness of our
Processing based on such consent before it was withdrawn,
including processing related to existing contracts for our
Services.
Right to Lodge a Complaint with a
DPA. If you believe our
Processing of Personal Data about you is inconsistent with the
applicable data protection laws, to lodge a complaint with your
local supervisory data protection authority (“DPA”).
To exercise any of the above listed
rights, please contact us as set forth below and provide sufficient
details so that we can respond appropriately. We will process any
requests in accordance with applicable law and within a reasonable
period of time. We may need to verify the identity of the
individual submitting a request before we can address such request.
If the request relates to data our customers collect and process
through the EasyManage Services, we will refer the request to that
customer and will support them in responding to the request. For
EasyManage customers, certain information may be reviewed,
corrected and updated by logging into the EasyManage Services
account and editing the profile information.
Questions and Complaints. If you
have questions, concerns, or complaints about this Policy or our
privacy practices, please contact our Privacy Officer by email
at info@EasyManage.com.
Compelled Disclosures. 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.
C.
CONTACT INFORMATION
If you have any questions, requests or
comments about this Privacy Policy, please do not hesitate to
contact us at:
Website: https://www.EasyManage.com/
Email: info@EasyManage.com
CALIFORNIA
SUPPLEMENTAL PRIVACY NOTICE,
LAST
UPDATED: January 11, 2021
This Privacy Notice for California
Residents supplements the information contained in the EasyManage
Privacy Policy and applies solely to all visitors, users, and
others who reside in the State of California (“User,”
”Consumer” or “you”). We adopt this notice
to comply with the California Consumer Privacy Act of 2018 (CCPA),
as amended, and any terms defined in the CCPA have the same meaning
when used in this notice.
INFORMATION
EASYMANAGE COLLECTS
Our Website collects information that
identifies, relates to, describes, references, is capable of being
associated with, or could reasonably be linked, directly or
indirectly, with a particular Consumer or household (”Personal
Information”). In particular, EasyManage’s Website has
collected the following categories of Personal Information from its
Consumers within the last twelve (12) months:
-
|
Category
|
Examples
|
Collected
|
|
A.
Identifiers
|
Name,
alias, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account
name, Social Security number, driver’s license number,
passport number, or other
similar identifiers.
|
Yes
|
|
B.
Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e))
|
Name,
signature, Social Security number, physical characteristics or
description, address, telephone number, passport number,
driver’s license or state identification card number,
insurance policy number, education, employment, employment
history, bank account number, credit card number, debit card
number, or any other financial information, medical information,
or health insurance information.
|
Yes
|
|
C.
Protected classification characteristics under California or
federal law
|
Age (40
years or older), race, color, ancestry, national origin,
citizenship, religion or creed, marital status, medical
condition, physical or mental disability, sex (including gender,
gender identity, gender expression, pregnancy or childbirth and
related medical conditions), sexual orientation, veteran or
military status, genetic information (including familial genetic
information).
|
No
|
|
D.
Commercial information
|
Records
of personal property, products or Services purchased, obtained,
or considered, or other purchasing or consuming histories or
tendencies.
|
Yes
|
|
E.
Biometric information
|
Genetic,
physiological, behavioral, and biological characteristics, or
activity patterns used to extract a template or other identifier
or identifying information, such as, fingerprints, faceprints,
and voiceprints, iris or retina scans, keystroke, gait, or other
physical patterns, and sleep, health, or exercise data.
|
No
|
|
F.
Internet or network activity
|
Browsing
history, search history, information on a Consumer’s
interaction with a Website, application, or advertisement.
|
Yes
|
|
G.
Geolocation data
|
Physical
location or movements.
|
Yes
|
|
H.
Sensory data
|
Audio,
electronic, visual, thermal, olfactory, or similar information.
|
No
|
|
I.
Professional or employment-related information
|
Current
or past job history or performance evaluations.
|
Yes
|
|
J.
Non-public education
information
|
Education
records directly related to a student maintained by an
educational institution or
party acting on its behalf, such as grades, transcripts, class
lists, student schedules, student identification codes, student
financial information, or student disciplinary records.
|
No
|
|
K.
Inferences drawn from other personal information
|
Profile
reflecting a person’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
|
No
|
USE
OF PERSONAL INFORMATION
We may use, or disclose the Personal
Information we collect for one or more of the following business
purposes:
As described in the General Privacy
Policy, Section A.2.
To fulfill or meet the reason you
provided the information. For example, if you share your name and
contact information to request a price quote, ask a question about
our products or Services, or register for an event, we will use
that Personal Information to respond to your inquiry. If you
provide your Personal Information to purchase a product or service,
we will use that information to process your payment and facilitate
delivery. We may also save your information to facilitate new
product orders or process returns.
As described to you when collecting your
Personal Information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger,
divestiture, restructuring, reorganization, dissolution, or other
sale or transfer of some or all of EasyManage’s assets,
whether as a going concern or as part of bankruptcy, liquidation,
or similar proceeding, in which personal information held by
EasyManage about our Website Users is among the assets transferred.
EasyManage will not collect additional
categories of personal information or use the Personal Information
we collected for materially different, unrelated, or incompatible
purposes without providing you notice.
SHARING
PERSONAL INFORMATION
EasyManage may disclose your Personal
Information to a third party for a business purpose. When we
disclose Personal Information for a business purpose, we enter a
contract that describes the purpose and requires the recipient to
both keep that Personal Information confidential and not use it for
any purpose except performing the contract.
We share your Personal Information with
the following categories of third parties:
Disclosures of Personal Information for
a Business Purpose
In the preceding twelve (12) months,
EasyManage has disclosed the following categories of Personal
Information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records
Personal Information categories.
Category D: Commercial information.
Category F: Internet or network activity.
Category I: Professional or
employment-related information.
We disclose your Personal Information for
a business purpose to the following categories of third parties:
Service providers
Partners
Sales of Personal Information
In the preceding twelve (12) months,
EasyManage had not sold Personal Information.
YOUR
RIGHTS AND OPTIONS
The CCPA provides Consumers (California
residents) with specific rights regarding their Personal
Information. This section describes your CCPA rights and explains
how to exercise those rights.
Data Access and Portability Rights
You have the right to request that
EasyManage disclose certain information to you about our collection
and use of your Personal Information over the past 12 months. Once
we receive and confirm your verifiable Consumer request (see
Exercising Access, Data Portability, and Deletion Rights), we will
disclose to you:
The categories of Personal Information we
collected about you.
The categories of sources for the
Personal Information we collected about you.
Our business or commercial purpose for
collecting that Personal Information.
The categories of third parties with whom
we share that Personal Information.
The specific pieces of Personal
Information we collected about you (also called a data portability
request).
If we disclosed your Personal Information
for a business purpose, two separate lists disclosing:
Deletion Request Rights
You have the right to request that
EasyManage delete any of your Personal Information that we collected
from you and retained, subject to certain exceptions. Once we
receive and confirm your verifiable Consumer request (see Exercising
Access, Data Portability, and Deletion Rights), we will delete (and
direct our service providers to delete) your Personal Information
from our records, unless an exception applies.
We may deny your deletion request if
retaining the information is necessary for us or our service
provider(s) to:
Complete the transaction for which we
collected the Personal Information, provide a good or service that
you requested, take actions reasonably anticipated within the
context of our ongoing business relationship with you, or otherwise
perform our contract with you.
Detect security incidents, protect
against malicious, deceptive, fraudulent, or illegal activity, or
prosecute those responsible for such activities.
Debug products to identify and repair
errors that impair existing intended functionality.
Exercise free speech, ensure the right of
another Consumer to exercise their free speech rights, or exercise
another right provided for by law.
Comply with the California Electronic
Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed
scientific, historical, or statistical research in the public
interest that adheres to all other applicable ethics and privacy
laws, when the information’s deletion may likely render
impossible or seriously impair the research’s achievement, if
you previously provided informed consent.
Enable solely internal uses that are
reasonably aligned with Consumer expectations based on your
relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of
that information that are compatible with the context in which you
provided it.
Exercising Your Rights
To exercise the access, data portability,
and deletion rights described above, please submit a verifiable
Consumer request to us by either:
Only you, or a person registered with the
California Secretary of State that you authorize to act on your
behalf, may make a verifiable Consumer request related to your
Personal Information. You may also make a verifiable Consumer
request on behalf of your minor child. You may only make a
verifiable Consumer request for access or data portability twice
within a 12-month period. The verifiable Consumer request must:
Provide sufficient information that
allows us to reasonably verify you are the person about whom we
collected Personal Information or an authorized representative.
Describe your request with sufficient
detail that allows us to properly understand, evaluate, and respond
to it.
We cannot respond to your request or
provide you with Personal Information if we cannot verify your
identity or authority to make the request and confirm the Personal
Information relates to you.
Making a verifiable Consumer request does
not require you to create an account with us. We will only use
Personal Information provided in a verifiable Consumer request to
verify the requestor’s identity or authority to make the
request.
Response Timing and Format
We endeavor to respond to a verifiable
Consumer request within forty-five (45) days of its receipt. If we
require more time (up to 90 days), we will inform you of the reason
and extension period in writing. If you have an account with us, we
will deliver our written response to that account. If you do not
have an account with us, we will deliver our written response by
mail or electronically, at your option. Any disclosures we provide
will only cover the 12-month period preceding the verifiable
Consumer request’s receipt. The response we provide will also
explain the reasons we cannot comply with a request, if applicable.
For data portability requests, we will select a format to provide
your Personal Information that is readily useable and should allow
you to transmit the information from one entity to another entity
without hindrance in a list format preferred by EasyManage. We do
not charge a fee to process or respond to your verifiable Consumer
request unless it is excessive, repetitive, or manifestly unfounded.
If we determine that the request warrants a fee, we will tell you
why we made that decision and provide you with a cost estimate
before completing your request.
NON-DISCRIMINATION
We will not discriminate against you for
exercising any of your CCPA rights. Unless permitted by the CCPA, we
will not:
Deny you goods or Services.
Charge you different prices or rates for
goods or Services, including through granting discounts or other
benefits, or imposing penalties.
Provide you a different level or quality
of goods or Services.
Suggest that you may receive a different
price or rate for goods or Services or a different level or quality
of goods or Services.
However, we may offer you certain
financial incentives permitted by the CCPA that can result in
different prices, rates, or quality levels. Any CCPA-permitted
financial incentive we offer will reasonably relate to your Personal
Information’s value and contain written terms that describe
the program’s material aspects. Participation in a financial
incentive program requires your prior opt in consent, which you may
revoke at any time.
OTHER
CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light”
law (Civil Code Section § 1798.83) permits Users of our Website
that are California residents to request certain information
regarding our disclosure of Personal Information to third parties
for their direct marketing purposes. To make such a request, please
send an email to info@EasyManage.com
CHANGES
TO OUR PRIVACY NOTICE
EasyManage reserves the right to amend
this privacy notice at our discretion and at any time. When we make
changes to this privacy notice, we will post the updated notice on
the Website and update the notice’s effective date. Your
continued use of our Website following the posting of changes
constitutes your acceptance of such changes.
CONTACT
INFORMATION
If you have any questions or comments
about this notice, the ways in which EasyManage collects and uses
your information described herein (and in the EasyManage Privacy
Policy), your choices and rights regarding such use, or wish to
exercise your rights under California law, please do not hesitate to
contact us at:
Website: https://www.EasyManage.com/
Email: info@EasyManage.com
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