Last updated: May 28, 2018
European Union (“EU”) Data Subject Requests? For EU data subject requests, contact us by emailing firstname.lastname@example.org.
1. Our Services
- 1.1 Users; Cheers. Our users use our Services to send, receive and gather “Cheers”. A “Cheers” is a virtual “high-five”, which may also be accompanied by additional text, images, gifs, and other types of content that we allow the sender of a Cheers to transmit through the Services.
- 1.2 Administrators. Users with administrative permissions are able to see statistics regarding cheers usage (sending and receiving) in aggregate and individual levels.
2. What information about you do we collect?When you use Cheers for Peers, we collect information relating to you and your use of our Services from a variety of sources, described below. Later sections describe what we do with the information.
2.1 Information we collect directly from you includes:
- Registration information. You need a Cheers for Peers account before you can use our Services. When you register for an account, we collect and store all registration information you provide, which may include details such as your name, email address, and employment information.
- Account settings. You can set various preferences and personal details on your Settings page.
- Cheers you intentionally send. We collect your personal information and other data if you intentionally submit it to us in a cheers or through other features of the Services, or in other contexts. For example, if you provide us with a testimonial, participate in a contest, or send us an email with comments or suggestions.
- Cookies and other tracking information. We collect usage data, device data, referral data, and information from cookies and page tags. Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for.
2.2 Information about you that we collect from third parties.
- We use third-party vendors to collect information about you and your use of our Services to provide us with analytics and tools to manage, improve, market and expand our Services.
- 2.1 Information we collect directly from you includes:
3. What do we do with the information we collect?
- Cheers. We store and maintain user Cheers submitted to the Services. Cheers are made available to other users from your organization (our customer), such as administrators and managers, based upon their permitted level of access. If you are a user, please contact the administrator who signed you up for the Services to understand how they will use the Cheers for your organization.
- Usage data. We may also analyze user usage patterns to improve or optimize our services.
To manage our services. We internally use your information, including certain Cheers, for the following limited purposes:
- To monitor and improve our services and features. We internally perform statistical and other analysis on information we collect (including usage data, device data, referral data, and information from page tags) to analyze and measure user behavior and trends, to understand how people use our services, and to monitor, troubleshoot and improve our Services.
- To prevent potentially illegal activities.
- To screen for undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud.
- To create new services, features or content (public data and metadata only). We may use public Cheers for Peers data and anonymized Cheers metadata (that is, data about the characteristics of Cheers but not its non-public content), to create and provide new services, features or content. For example, we may look at statistics like the number of Cheers per organization, Cheers word counts, and Cheers sent and received per capita, and publish interesting observations about these for informational or marketing purposes.
- To contact you about your account. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, or a welcome email when you first register). You cannot opt out of these communications since they are required to provide our Services to you.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
Cookies We use information we obtain from cookies for several reasons:
4. How do we share the data we collect about you?Rest assured that we do not sell your email address, Cheers content, or other information to third parties, and we only disclose your information to third parties (other than those in your organization) for a limited number of reasons:
- Your account details to your billing contact. If your details (as the account holder) are different to the billing contact listed for your account, we may disclose your identity and account details to the billing contact upon their request (we also will attempt to notify you of such requests).
- Research. We may disclose aggregated, anonymous, or anonymized data, including aggregated and anonymous Cheers, to third parties for market research, academic research, benchmarking, forecasting, trend research, or any other purpose. In all such instances, we will not disclose any identifiable information about users or our customers.
- The presence of a cookie to advertise our services. We may ask advertisers to display ads promoting our Services on other websites. We may ask them to deliver those ads based on the presence of a cookie but in doing so will not share any other information with the advertiser.
- Change in business ownership or structure.If ownership of all or substantially all of our business changes, or we undertake a corporate reorganization (including a merger or consolidation) or any other action or transfer between our related entities. We will provide notice of such a transfer in accordance with applicable laws.
- Information you expressly consent to be shared. For example, we may expressly request your permission to provide your contact details to third parties for various purposes, including to allow those third parties to contact you for marketing purposes. (You may later revoke your permission, but if you wish to stop receiving communications from a third party to which we provided your information with your permission, you will need to contact that third party directly.)
5. Do we publicly share your information?Yes, in certain circumstances. Information you submit to publicly accessible blogs or community forums available through our Services may be read, collected, and used by others who access them. We’re not responsible for any personal information you choose to submit in these publicly accessible areas of our Services.
6. Safety of Minors and COPPA.Our Services are not intended for and may not be used by minors. "Minors" are individuals under the age of majority in their place of residence (or under 13 in the United States or under age of 16 in the European Union). We do not knowingly collect personal data from minors or allow them to register as users. If it comes to our attention that we have collected personal data from a minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact us at email@example.com or firstname.lastname@example.org regarding an EU data subject.
7. What are your rights to your information?You can:
- Update your account details. You can update your registration and other account information on your Settings page.
- Capture your Responses.You can take screenshots of your information and data, including but not limited to Cheers. We may in our discretion provide other tools to export the data.
- Cancel your account. Deleting your account will not cause all the Cheers in the account to be permanently deleted, but will disable your access to any other Services that require a Cheers for Peers account.
- Submit a request. You can submit a request by email to email@example.com or to firstname.lastname@example.org for EU data subjects. We will respond to your request, including any appropriate request to access, correct, update, restrict processing or object to processing, or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfill requests to delete personal data unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law). If we are processing your personal data on behalf of a customer, we will promptly refer your request to our customer and support the customer in responding to your request.
8. For how long do we retain your data?We retain your data as long as necessary to provide our Services and to comply with our legal obligations. Within thirty (30) days after your data is no longer needed to provide our Services or comply with our legal obligations, we anonymize and aggregate your data permanently. However, we reserve the right to delete or purge such data.
9. Third Party Data SourcesWe obtain information about prospective customers and users from third party sources including data licensors and marketing company databases. We use the information to market our Services.
10. SecurityThe security of your data and information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information submitted to us, intended to protect it from unauthorized access, destruction, use, modification, or disclosure. However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure, and we are unable to guarantee the absolute security of your data and information. More information can be found at https://www.tinypulse.com/platform-security.
11. Supplemental Notice to EU Data SubjectsWe process personal data for the limited purposes identified above.
- 11.1 Lawful Grounds. If you reside in the European Economic Area or Switzerland (collectively the “EU”), we rely on the following lawful grounds under the General Data Protection Regulation (“GDPR”) to process (collect, store, and use) your personal data: (a) it is necessary for the performance of a contract with you; (b) our or a third-party’s legitimate business interest; or (c) your consent.
- 11.2 Data Transfer Notice.We transfer your personal data to the United States and Vietnam for processing in the United States and Vietnam. We make the transfer to the United States and Vietnam in the absence of an adequacy decision because it is necessary for the performance of a contract with you, or with your explicit consent.
- 11.3 Individual Rights and Data Subject Requests. We provide you with tools to change access, delete, or modify your personal information within the Services. We also provide tools to our customers to respond to your data subject request within the Services. Additionally, you may also contact us at email@example.com to request access to, transfer of, and rectification or erasure of your personal data, or restriction of processing, or to object to processing of your personal data. If sending an email, please specify the nature of your request and the information that is the subject of your request. We may require you to submit additional information necessary to verify your identity and status as an EU data subject. We will respond to your request within 30 days.
- 11.4 Withdraw Consent. If we are processing your personal data based upon the lawful ground of your consent, you have the right to withdraw your consent for such processing at anytime without affecting the lawfulness of processing based on consent before it is withdrawn. To withdraw consent, email us at firstname.lastname@example.org.
18 West Mercer St, Seattle, WA 98119
+1 (206) 455 9424
email@example.com or if you are in the EU at firstname.lastname@example.org.