Etleap Inc. ("Etleap") respects individual privacy and values the confidence of its associates, customers, vendors and those with whom we do business. Etleap strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which we do business.

EU-US and Swiss-US Privacy Shield

Etleap complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from transferred from the European Union and Switzerland to the United States, respectively. Etleap has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Scope

This Privacy Shield Policy sets forth the privacy principles that Etleap follows with respect to transfers of personal information between member states of the European Union, Iceland, Liechtenstein and Norway (the European Economic Area or EEA), Switzerland and the United States. Etleap is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Definitions

"Personal Information" or "Information" means information that (1) is transferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

"Sensitive Personal Information" means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

What Data We Collect

Information Provided by Visitors: If you visit our website, we may collect Personal Information from you, including, but not limited to, first and last name, organization name, e-mail address and password if you decide to register to receive information, schedule a demo, or create an account to use Etleap's services ("the Services"). If you provide us feedback or contact us via e-mail (e.g., in response to an employment opportunity posted on our website), we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply, and any information that you submit to us, such as a resume.

Information that we may collect via technological means: Our servers (which may be hosted by a third-party service provider) may collect data from you, such as browser type, operating system, IP address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. Like most Internet services, we automatically gather this data and store it in log files each time you visit our website or access your account on our network. We may also directly collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Service.

Information that we may collect from our Customers: If you decide to purchase the Services and become a Etleap customer, you will need to set up your profile to be able to use the Services. This includes, among other things, telling us how to contact you or your organization when there are ETL events we need to notify you about, and creating accounts for your team members. You will be required to provide the applicable contact information ("Contact Information"), parts of which will also be Personal Information. If you or your Users are supplying Personal Information for contact persons, your represent and warrant that you have the right to provide such information.

How We Use the Data We Collect

We use Personal Information for two basic purposes: to provide and improve our website and to provide and improve the Services. In particular, we use Contact Information to send alerts to Customers in accordance with the Customer’s notification rules.

We may also use Personal Information to facilitate the creation of and secure your account on our network; identify you as a User in our system; provide improved administration of our website and Services; improve the quality of experience when you interact with our website and Services; respond to your inquiries related to employment opportunities or other requests; send promotional communications; provide you with hardcopy or electronic newsletters, or surveys; send upgrades and special offers related to our Services and related services and for other marketing purposes of Etleap, should you request to receive such communications from us; make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback. We may also analyze request and usage patterns so that we may enhance the content of the website and Services or improve their respective functionalities, or for other business purposes.

We may provide your Personal Information or other information to third-party service providers who work on behalf of or with us to provide or enable some of the services and/or features of our website and Services or to help us communicate with you. Examples of such services include sending e-mail, analyzing data, providing marketing assistance, providing assistance in operating the website and Services and providing customer service. We require our third-party service providers to agree not to use such information except as necessary to provide the relevant services to us and you. However, once we have disclosed your information, including Personal Data, to a third party as described in this Privacy Policy, we cannot control and assume no responsibility for the manner in which that third party uses or further discloses such information.

Disclosure to Law Enforcement

Etleap may disclose Personal Data, including the data you submit to us, with or without notice (a) if required by a subpoena or other judicial or administrative order, (b) where required by law, or (c) at our sole discretion, where we deem it necessary to protect the safety of any individual, the general public, or to prevent violation of the rights of Etleap or any third party. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Etleap and Its Affiliates

Etleap is a United States based corporation, which also operates several international affiliates. Etleap may share some or all of your Personal Data with these, or future, affiliates. Etleap requires all affiliates to honor its Privacy Policies, including the Privacy Shield Policy.

Change of Ownership

In the event of change in ownership, or a direct merger or acquisition with another entity, we reserve the right to transfer all of Etleap User information, including Personal Data, to a separate entity. We will use commercially reasonable efforts to notify you (by posting on our website or issuing an e-mail to the e-mail address you provided when you registered) of any change of ownership; merger or acquisition of Etleap by a third party, and you may choose to modify any of your registration information at that time.

Principles

Notice

Etleap shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which the Company discloses or may disclose that Information. Company shall provide the Individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which is was originally collected.

Choice

The Company will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (1) to be disclosed to a non-agent third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, Etleap will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of their information to a non-agent third party or the use of their information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

We may periodically send you free newsletters and e-mails that directly promote the use of our site or the purchase of our Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" (either through your account or by following the unsubscribe instructions provided in the e-mail you receive).

Onward Transfers

Etleap will obtain assurances from its agents that they will safeguard personal information consistent with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Privacy Shield Principles, being subject to EU Directive 95/46/EC (the Data Protection Directive), Privacy Shield certification by the agent, or being subject to another European Commission adequacy finding. Where Etleap has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Etleap will take reasonable steps to prevent or stop the use or disclosure. In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-US or Swiss-US Privacy Shield, Etleap is potentially liable.

Security

Etleap shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Etleap has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Etleap cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity and Purpose Limitation

Etleap shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Etleap shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access

Upon request, Etleap will grant individuals reasonable access to personal information that it holds about them. In addition, Etleap will take reasonable steps to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

Recourse, Enforcement and Liability

Etleap uses a self-assessment approach to maintain compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with these Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

Dispute Resolution

In compliance with the EU-US Privacy Shield Principles and Swiss-US Privacy Shield Principles, Etleap commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Etleap at:

Etleap Inc.
Re: EU-US or Swiss-US Privacy Shield
340 S Lemon Ave #9232
Walnut, CA 91789
info@etleap.com

Etleap has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under certain limited conditions, last resort binding arbitration may be available before a Privacy Shield Panel.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of the Privacy Shield. We will post any revised policy on this website.

Information Subject to Other Policies

The Company is committed to following the Principles for all Personal Information within the scope of the Privacy Shield Agreement. However, certain Information is subject to policies of the Company that may differ in some respects from the general policies set forth in this privacy policy.

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