SOFTWARE PRIVACY POLICY

Effective: 01.01.2020

Last Reviewed on: 07.30.2020

1. Introduction

At Concord Technologies Inc. (“Concord” or “we”), protecting your privacy is extremely important to us. As we provide privacy-first data solutions that protect and reward people and the brands they engage with, we know how important it is to be able to understand what information is being collected about you, what it is used for, and how it is protected. The Concord application (the “Service”) is made available to you to allow you to create a profile of your personal information, preferences, demographic information, interests, consent, and other data. You may choose which third parties may access this information and control that access through the features made available in the Service.

This policy describes:

  1. The types of information we may collect or that you may provide to us when you register to use the Service, or register with one of our customers to use the Service, when you provide information to us or to our customers through the Service, or when you download, access, or otherwise use the Service; and
  2. Our practices for collecting, using, maintaining, protecting, and disclosing your information.

This policy applies only to information we collect through the Service (whether through the Concord application that we make available or our plugins or other Service options made available by our customers on their websites or applications) and in email, text, and other communications sent to us directly through the Service.

This policy DOES NOT apply to information that:

  1. Is collected on any third-party website (including websites you may access through the Service);
  2. Is collected by any third-party (see "Third-Party Information Collection" below); or
  3. You choose to provide to our customers who use the Concord plugins or other Service options (the customer’s privacy policy will apply to any information you provide to such customer).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this Service. By downloading, registering with, or using this Service, you agree to this privacy policy. This policy may change from time to time (see "Changes to Our Privacy Policy" below). Your continued use of this Service after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Pursuant to Section Cal. Civ. Code § 1798.140(c), we are not required to comply with the California Consumer Privacy Act (“CCPA”). However, due to our commitment to privacy and transparency, we strive to follow CCPA guidelines. Please see Section 9 "For California Residents – Accessing & Correcting Your Personal Information" for more Information.

2. Information We Collect About You

We collect information from and about users of our Service:

  • Directly from you when you provide it to us;
  • Automatically from you when you use the Service;
  • From our customers, when you use our plugins or other Service options on our customer’s website;
  • From third-party websites or applications, if you allow us access to information from these sources; or
  • Web traffic sources.

Specific types of information we DO collect, in each case if you provide it to us, and in each case this information may be shared with our third-party service providers, or our customers if you choose to share it with our customers:

  • Identifiers: such as real name, alias, postal address, unique personal identifier, online identifier, Internet, Protocol address, email address, account name, number, or other similar identifiers;
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): such as a name, signature, physical characteristics or description, address, telephone number, education, employment, employment history;
  • Protected classification characteristics: such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, gender expression, sexual orientation, veteran or military status;
  • Commercial information: such as products or services purchased, obtained, considered or other purchasing or consuming histories or tendencies;
  • Biometrics: such as 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;
  • Internet or network activity: such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement;
  • Geolocation: such as physical location or movements;
  • Professional or employment related information; or
  • Inferences drawn from other information: such as profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Specific types of Information we DO NOT collect:

  • Sensitive Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
  • Sensory data: Audio, electronic, visual, thermal, olfactory, or similar information; or
  • Non-public education information.

3. How We Collect Information

The above categories of information may be collected as follows:

  • When you fill out forms in the Service;
  • When you provide it through our website plugins or other Service options hosted on our customer’s websites;
  • At the time of registering to use the Service or through your ongoing use of the Services;
  • By using the features of the Service (such as identifying preferences or providing demographic information directly to us);
  • When you enter a contest or promotion;
  • When you communicate with us or report a problem with the Service or change your preferences within the Service;
  • When you correspond with us (including email addresses and phone numbers);
  • When you complete surveys;
  • Transactions you carry out through the Service our through our customers, such as the fulfillment of your orders;
  • Search queries on the Service; or
  • From third parties (such as browser history, purchase history, or other activity).

When you download, access, or use the Service, the Service may use technology to automatically collect:

  • Usage Details. When you access and use the Service, we may automatically collect certain details of your access to and use of the Service, including traffic data, location data, logs, information about your operating system and other communication data and the resources that you access and use on or through the Service.
  • Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
  • Stored Information and Files. The Service also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
  • Location Information. This Service may collect real-time information about the location of your device automatically.

The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our Service.
  • Web Beacons. Pages of the Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages [or opened an email] and for other related Service statistics (for example, recording the popularity of certain Service content and verifying system and server integrity).
  • Device Finger Printing. Device fingerprinting is the process of analyzing and combining sets of information elements from your device’s browser, such as JavaScript objects and installed fonts, in order to create a “fingerprint” of your device and uniquely identify your device and apps.

We may link, combine or supplement the information you provide us with other information we receive from third-party Sources or with cookies. We do this to help understand your needs and provide you with better services, to identify you when you return to our site or to pre-populate forms. We may use anonymous, aggregated information for different purposes, like market analysis, traffic flow analysis and reporting, or to deliver relevant advertising and information based on click stream data. We may also use this information to examine our traffic in aggregate, to investigate misuse of our network, its users, or to cooperate with law enforcement.

We may also use these technologies to collect information about your activities over time and across third-party websites, Services, or other online services (behavioral tracking). Some browsers have incorporated ‘Do Not Track’ features. Most of these features, when turned on, send a signal or preference (a "DNT Signal”) to the web sites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret DNT Signals, nor a common definition of tracking, we do not currently respond to DNT Signals across all browsers, although we do attempt to respond to certain browsers DNT Signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

4. Third-Party Information Collection

When you use the Service, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Our customers who install our plugins or other Service options on their website(s) or applications;
  • Your mobile device manufacturer;
  • Your mobile service provider; or
  • Our infrastructure or platform providers.

These third parties may use tracking technologies to collect information about you when you use this Service. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, services, and other online services websites or applications. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, please see the “Choices About How We Collect, Use, and Disclose Your Information” section below.

5. How We Use Your Information

We use the information that we collect about you or that you provide to us, including any personal information, to:

  • Provide you with the Service and its contents, other information, or products or services that you request from us or our customers;
  • Fulfill any other purpose for which you provide it;
  • Give you notices about your account;
  • Carry out our obligations and enforce our rights arising from any contracts we enter into;
  • Notify you when Service updates are available, and of changes to any products or services we offer or provide though it;
  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry;
  • To provide, support, personalize, or develop our website or services;
  • To create, maintain, customize, or secure your account with us;
  • To process your requests, transactions, or payments and prevent transactional fraud;
  • To provide you with support or to respond to your inquiries, including to investigate or address your concerns and monitor and improve our responses;
  • To personalize your experience;
  • To deliver content and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law);
  • To help maintain the safety, security, and integrity of our website or services, databases and other technology assets, and business;
  • For testing, research, analysis, or product development, including to develop and improve our website or Service;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • As described to you when collecting your personal information;
  • To analyze your personal information (including through the use of automated processes) in order to create a profile of your interests and preferences; or
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Concord Technologies Inc. assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Concord Technologies Inc. users is among the assets transferred.

The usage information we collect helps us to improve our Service and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns;
  • Store information about your preferences, allowing us to customize our Service according to your individual interests;
  • Speed up your searches; and
  • Recognize you when you use the Service.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see the “Choices About How We Collect, Use, and Disclose Your Information” section below.

6. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction (this information does not identify any individual and is not personally identifiable information).

We disclose personal information to:

  • Service providers, for business purposes;
  • Our customers, upon your consent and in connection with their contract for services; or
  • Other entities, with your consent.

We may disclose your personal information to a third party for a “business purpose” which is defined as (i) an operational purpose, or other notified business purpose, or (ii) use that is reasonably necessary in connection with the purpose in which the personal information is provided or another contextually compatible operational 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 to not use it for any purpose except performing the contract.

Business purposes include:

  • Auditing the interaction with the consumer and concurrent transactions, including counting ad impressions and verifying quality of ad impressions;
  • Detecting or preventing security incidents or other illegal activity and prosecuting the responsible parties;
  • Debugging;
  • Short-term, transient use if the personal information is not:
  • ~disclosed to another third party; or
  • ~used to build a profile or otherwise alter an individual consumer's experience outside the current interaction.
  • Service providers such as customer service, order fulfillment, payment processing, financing and advertising, marketing, or analytic services, infrastructure or data security related services;
  • Undertaking internal research for technological development and demonstration; or
  • Verifying or maintaining quality or safety or improving or upgrading a service or device owned, manufactured, or controlled by or for the business.

In addition, we may disclose personal information that we collect:

  • With your consent;
  • To our subsidiaries and affiliates;
  • To our customers (with your consent);
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Concord Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Concord Inc. about our Service users is among the assets transferred;
  • To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website or Service, we will transmit the contents of that email and your email address to the recipients;
  • For any other purpose disclosed by us when you provide the information;
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • To enforce our rights arising from any contracts entered into between you and us; or
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Concord, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

7. Choices About How We Collect, Use, & Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Service may then be inaccessible or not function properly.
  • Location Information. You can choose whether or not to allow the Service to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Service may then be inaccessible or not function properly.
  • Promotion by the Company. If you do not want us to use your contact information to promote our own or third parties’ products or services, you can opt-out by logging into the Service and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes.
  • Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes.
  • Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by logging into the Service and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.

8. Accessing & Correcting Your Information

You can review and change your personal information by logging into the Service and visiting your account profile page. You may also send us an email at privacy@concord.tech to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California residents may have additional personal information rights and choices. Please see the “For California Residents – Accessing & Correcting Your Personal Information” section below for more information.

9. For California Residents – Accessing & Correcting Your Personal Information

Pursuant to Section Cal. Civ. Code § 1798.140(c), we are not required to comply with the California Consumer Privacy Act (“CCPA”). However, due to our commitment to privacy and transparency, we strive to follow CCPA guidelines.

Please note that, because we are not required to comply with the CCPA, we expressly disclaim any liability to you arising from or related to our failure to comply with the CCPA.

If you are a resident of California, you have the right to request that we 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 or selling 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); or
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • ~sales, identifying the personal information categories that each category of recipient purchased; and
  • ~disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

If you are a resident of California, you have the right to request that we 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, 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; or
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If you are a resident of California, to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Contacting us via the mechanism in the Service.
  • Sending an email to privacy@concord.tech.
  • Calling us at 833-444-2673.

Only you, or someone legally authorized 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; and
  • 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. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 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.

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.

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.

10. Data Security

We have implemented measures which are designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our servers behind firewalls. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Service. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

11. Children Under the Age of 16

The Service is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@concord.tech.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see the “For California Residents – Accessing & Correcting Your Personal Information” section above for more information.

12. Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and notify you by email and/or an in-Service alert the first time you use the Service after we make the change.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

13. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, please email us at privacy@concord.tech or call us at 833-444-2673.