Last Revised: July 21, 2018
EU-US and Swiss-US Privacy Shield
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. 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 Services. 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 end 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 an end user in our system; provide customer support and improved administration of our website and Services; improve and personalize 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 information that we believe may be useful to you, such as information about the Services, 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 our website and Services or improve their respective functionalities, or for other business purposes.
We may use financial information or payment method to process payment for any purchases, subscriptions or sales made on our website or in connection with our Services, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
In addition, we may use the Personal Information we obtain about you in other ways for which we provide notice at the time of collection or with your consent.
Our Services include ETL (Extract, Transform, and Load) data integration, extraction and management software applications which automate various business processes and are intended for enterprise business customers and not for individuals. Depending on the specific Service, we process different types of data uploaded to our online platforms and hosted software applications by Customers. The exact data elements to be transferred and data retention are controlled and defined by each Customer or the owner of the domain associated with your email address if the Service is used by your organization, employer or the company which originally collected your data. Consequently, while we process the data the End Users originally transferred to our Customer that can include Personal Information about such End Users, we cannot assume responsibility for the information or content you transferred to the Customer. Etleap has no direct relationship with the End Users or other individuals whose Personal Information it processes as part of Customer’s data. Each Customer is responsible for providing notice to its End Users and third persons concerning the purpose for which a Customer collects their Personal Information and how this Personal Information is processed through the Services.
Disclosure to Law Enforcement
Etleap may use your Personal Information to comply with applicable laws, regulations, or legal process as well as industry standards and our company policies, to prevent fraud or other misuse, including by protecting our rights and the rights of affiliates or related third parties and to enforce our Terms of Service and other policies of Etleap.
In particular, Etleap may disclose Personal Information, 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 © 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.
Change of Ownership
In the event of change in ownership, a direct merger or acquisition with another entity, reorganization or liquidation, we reserve the right to transfer all of the information we collect through our website and End User information, including Personal Information, to another entity involved in the transaction.
Your account is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including only authorized access, role- based access control models, two-factor authentication for server access, encryption, firewalls and transport layer security technology.
Although we maintain physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our Services, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. In the event of a data breach we will use commercially reasonable efforts to report to any and all relevant persons and authorities promptly following our discovery of the breach if it is apparent that Personal Information stored in an identifiable manner has been stolen or otherwise compromised.
Links to Other Websites
Our website may contain hyperlinks to other websites or online locations for your convenience and information. Those linked websites may be operated by unaffiliated entities, such as our Customers, and may have their own privacy policies, statements or notices.
Our website is not intended for children, nor is it targeted to children under the age of thirteen. We do not knowingly collect personal information from children under the age of 13 through the website, and if we learn that we have received information from a visitor under the age of 13, we will delete such information in accordance with applicable law.
California Privacy Rights
California law permits customers in California to request certain details about how their information is shared with third parties and, in some cases, affiliates for direct marketing purposes. Under the law, a business must either provide this information or permit California customers to opt in to, or opt out of, this type of sharing. We do not share Personal Information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. California customers may request information about our compliance with this law by contacting us at email@example.com, or by postal mail to Etleap, Inc., 340 S Lemon Ave #9232, Walnut, CA 91789. Any such inquiry must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address.
Any California residents under the age of eighteen (18) who have registered to use our website, and who have posted content or information on the website, can request that such information be removed from the site by contacting us at firstname.lastname@example.org, stating that they personally posted such content or information and detailing where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal.
Information for Persons Outside the United States
Legal Basis for Processing (EEA only)
If you are an individual from the EEA, our legal basis for collecting and using the Personal Information will depend on the Personal Information concerned and the specific context in which we collect and use it. As explained above, we process Personal Information in various ways depending upon your use of our website and the Customers’ use of our Services. We process Personal Information on the following legal bases: (1) with your consent; (2) as necessary to perform a contract when you request services or products; and (3) as necessary for our legitimate interests in enhancing our services and products and providing you with marketing materials and other information. We also collect Personal Information where we need to provide Services to a Customer under an agreement with such Customer, in which case we may be acting as a data processor or sub-processor.
Your Rights under the EU Privacy Law
If you are an individual in a European Union member state or in a EEA country, you have the following rights:
Right to Lodge a Complaint. You have the right to lodge a complaint about our data collection and processing actions with respect to the Personal Information you provided to Etleap directly through our website with the data protection authority in the jurisdiction where you reside.
Right to Erasure. You have the right to request that Personal Information you provided to Etleap directly through our website about you be deleted or erased. If deletion of your Personal Information should not be possible for technical or legal reasons, we may block the respective data instead.
To request deletion or blocking of Personal Information, or revoke previously granted consent, please contact us at email@example.com.
Right to Revoke Consent for Processing of Personal Information. If you consented to Etleap’s processing of your Personal Information you have provided to us directly through our website, you have the right to revoke the consent you previously provided.
To revoke previously granted consent, please contact us at firstname.lastname@example.org.
Right to Data Portability. You have the right to request that the Personal Information you have provided directly to Etleap through our website, which we process by automated means, be provided to you or another controller in a structured, commonly used and machine-readable format.
Re: EU-US or Swiss-US Privacy Shield
340 S Lemon Ave #9232
Walnut, CA 91789
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.
Information Subject to Other Policies