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, INC. 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, 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: DPO@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:

    1. GENERAL PRIVACY POLICY

      1. Information We May Collect

      2. Use of Information

      3. Sharing of Information

      4. Cookies and Similar Technologies

      5. Data Retention

      6. Choices and Opt-Out

      7. Cross-Device Tracking

      8. Employment Opportunities

      9. Third-Party Sites

      10. Security

      11. Children

      12. Sensitive Personal Information

      13. International Data Transfers

      14. California Privacy Rights

      15. Questions, Complaints and Disputes

      16. Privacy Policy Updates

    2. European Privacy Policy

    3. Contact Information

A. GENERAL PRIVACY POLICY

1. INFORMATION WE MAY COLLECT

    1. 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.

    2. 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:

      1. Your first and last names and contact details, including residential address, telephone number, and email address

      2. Payment or financial information for billing purposes (credit card details)

      3. Your passwords and/or personal identification codes (PINs)

      4. Employer or organizational affiliation for a User of the EasyManage Services

      5. IP address or MAC address, and information derived from an IP or MAC address, such as geographic location

      6. Referring domain, destination domain and destination path

      7. Geolocation data

      8. User IDs and passwords for Users with accounts on the EasyManage Services

      9. Employee data regarding current position and employment history

      10. Your testimonials, feedback and complaints

      11. Browsing activities, cookies and similar data, and platform or mobile application use data

      12. Screen name

      13. Screen sharing views, at the request of Users, for support and quality assurance (“QA”) purposes

      14. Any data in any files uploaded, emailed or otherwise provided by Users for support and QA

      15. Operating system type and version, web server type and version, database type and version

      16. Unique IDs such as a cookie placed on a computer or mobile device, or device IDs

      17. Information about the performance, security, software configuration and availability of our software on your servers and network

      18. Statistics regarding use of the Sites and viewing activity records

      19. Communication preferences

      20. Other similar information


    1. 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:

      1. 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.

      2. 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.

      3. Support: Personal information may be collected in connection with User support, whether via screensharing, email, social media, telephone or otherwise.

      4. 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.

      5. 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.

      6. 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.

      7. 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

    1. 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.


    2. 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:

      1. to deliver certain of our Services from our Sites;

      2. to provide, maintain, and improve the Sites for internal or other business purposes;

      3. to fulfill User requests, such as to create a EasyManage Services account or to provide requested Services;

      4. 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;

      5. 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;

      6. 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;

      7. to respond to reviews, comments, or other feedback provided to us;

      8. to support, optimize, improve and personalize our Services, Sites, mobile services, and advertising, including tracking and evaluating the use of the Sites;

      9. to send newsletters or other materials;

      10. to populate online profiles of Users;

      11. to protect the security and integrity of our Services, content, and our business;

      12. for marketing purposes and to explore prospective sales leads;

      13. to check financial qualifications and collect payments;

      14. 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;

      15. in the case of server logs, to help us statistically monitor how many people are using our Site and for what purpose;

      16. to perform statistical, demographic, and marketing analyses of Users of the Sites and their viewing patterns;

      17. 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

      18. for any other lawful purpose for which the information is provided, including fulfilling requests for information.


    3. 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:

      1. diagnose and address software issues;

      2. provide hosting services;

      3. fulfill IT-related duties for technical maintenance and the backup of the hosting environment;

      4. provide services in relation to the installation and configuration of our software;

      5. assist with the preparation and migration of data to our software;

      6. develop product enhancements; and/or

      7. provide data capturing services.


    4. 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.


    5. 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.


    6. 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.


    7. 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.


    8. 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.


    9. 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

    1. To the extent permitted by applicable law, we may share and disclose information, including personal information, as set forth below:

      1. Customers. We may share information with our customers and their service providers and other platforms that may assist those customers.

      2. 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.

      3. 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).

      4. 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.

      5. 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.

      6. 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.

      7. 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).

      8. 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.

      9. 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,


    2. 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

    1. 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).


    2. 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.


    3. 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.


    4. We may use the following types of cookies and similar technologies:

      1. 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.

      2. 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.

      3. 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.

      4. 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.


    5. 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.

      1. 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.

      2. 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.

      3. 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

    1. 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

    1. 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.


    2. 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.


    3. 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:

      1. invite you to a user conference; and/or

      2. notify you about an existing or new product or service.

    4. 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: DPO@EasyManage.com.


7. CROSS-DEVICE TRACKING

    1. 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

    1. 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

    1. 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

    1. 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.


    2. 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.


    3. 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.


    4. 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

    1. 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

    1. 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.

    2. 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

    1. 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

    1. 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

    1. If you have questions, concerns, or complaints about this Policy or our privacy practices, please contact our Privacy Officer by email at DPO@EasyManage.com. We will respond to your inquiries as soon as is practicable.


      1. 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.

      2. 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

    1. 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.

    2. 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 DPO@EasyManage.com.

B. EUROPEAN PRIVACY POLICY

    1. The following European Privacy Policy applies if your personal data is processed in the European Union, the European Economic Area and/or Switzerland.


    2. Personal Data and Processing. For the purposes of this European Privacy Policy:

      1. 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

      2. 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.


    1. 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.


    2. 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.


    3. 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.


    4. Data Transfers:

    5. 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).


    6. 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.


    7. Additional Rights: Under European law, you may have one or more of the following additional rights:

      1. Access. To request a copy of the Personal Data we have collected about you by contacting us.

      2. Rectification & Erasure. To request that we rectify or delete any of the Personal Data about you that is incomplete, incorrect, unnecessary or outdated.

      3. Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes.

      4. 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.

      5. Data Portability. To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.

      6. 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.

      7. 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”).


    1. 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.


    2. 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 DPO@EasyManage.com.


    3. 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

    1. If you have any questions, requests or comments about this Privacy Policy, please do not hesitate to contact us at:


    2. Website: https://www.EasyManage.com/
      Email: DPO@EasyManage.com


    3. Postal Address:

      1. EASYMANAGE, INC.
        8 The Green Ste. 6466
        Dover, DE 19901
        Attention: Data Privacy Officer



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

  • Personal Information does not include:

    • Publicly available information from government records.

    • Deidentified or aggregated Consumer information

    • Information excluded from the scope of the CCPA, including:

      • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 ( HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

      • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

  • EasyManage obtains the categories of Personal Information listed above from the following categories of sources:

    • Directly from you. For example, from forms you complete or products and Services you use and/or purchase.

    • Indirectly from you. For example, from your activity on our Website

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:

    • As described in the General Privacy Policy, Section A.3.

  • 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:

      • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

  • 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:

    • Visiting https://www.EasyManage.com/

    • Emailing DPO@EasyManage.com

  • 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 DPO@EasyManage.com or write us at: 8 The Green, Ste. 6466, Dover, DE 19901.

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: DPO@EasyManage.com

  • Postal Address:

EasyManage, Inc.
8 The Green, Ste. 6466
Dover, DE 19901






 
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