Introduction

This privacy policy is designed to inform users of the Appsulate service (collectively, the “Service”) about how we gather and use personal information and user data collected by us in connection with use of the Service. We will take reasonable steps to protect user privacy consistent with the guidelines set forth in this policy and with applicable U.S. laws. In this policy, “user” or “you” means any individual or enterprise using the Service, whether as the enterprise customer purchasing the Service or an authorized user of the Service. BY ACCESSING OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND OUR TERMS OF SERVICE. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE SERVICE.

What Information Do We Collect?

Limited Personal Information: We collect the following personal information in connection with the Service: (a) when you register to use the Service on behalf of an enterprise (the “Licensee”) we will collect the business information for the Licensee enterprise, such as name and address, and contact details, such as name, email address, physical address and telephone, for a contact person at the enterprise; (b) when you register or are registered as an authorized user (an “Authorized User”) of the Service for your Licensee enterprise, we will collect the personal information you submit to us to build your user profile, including your name, email address, your organizational title, and additional information such as your responsibilities and projects within the enterprise; (c) if you pay your fees by credit card, we will collect the name, expiration date and credit card number for the relevant card; and (d) if you communicate with us by email, we will collect your email address. All of this information is referred to in this Policy as “Personal Information”.

Other Personal Information: Apart from the limited personal information described above, Appsulate does not collect and does not wish to receive any personally identifiable information. Without limitation, you shall not submit to Appsulate: (a) any social security number, financial account number, credit or debit card number (other than the number of the card paying for the Service), driver’s license number or government ID number; (b) any personal financial information that is protected by the Gramm-Leach-Bliley Act and regulations promulgated under it; or (c) any protected health information protected by the Health Insurance Portability and Accountability Act.

Document Security and Management Information: The Service is a cloud based document security and management application, designed for use by organizations and individuals that want to control access to and redistribution of their important documents by third party recipients. In order to the Service relies on documents supplied to Appsulate’s cloud based servers by Authorized Users and the Licenscee, or access credentials to external data sources that Authorized Users or Licensee link to the Service, and on data generated by use of the Service by all Authorized Users, including all email inquiries sent to Appsulate (collectively, all of this data is referred to in this Policy as the “User Data”).

Web Tracking Information: We, and our third party service providers, may use web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the Service efficiently and to collect data related to usage of the Service. Such collected data (“Web Tracking Information”) may include the address of the websites you visited before and after you visited the Service, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Service you visit and what links you clicked on, and whether you opened email communications we send to you. In order to collect Web Tracking Information and to make your use of the Service more efficient, we may store cookies on your computer. We may also use web tracking technologies that are placed in web pages on the Service or in email communications to collect information about actions that users take when they interact with the Service or such email communications, and Appsulate’s Contractors (as hereinafter defined) may also do so. We do not correlate Web Tracking Information to individual user Personal Information. Some Web Tracking Information may include data, such as IP address data, that is unique to you. You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the Service, but this may affect the performance of the Service.

How Do We Use the Information We Collect?

Personal Information: We will use and store Personal Information for the purpose of delivering the Service to you, and to analyze and enhance the operation of the Service. We may also use Personal Information for the internal operational and administrative purposes of the Service.

User Data: Appsulate collects and stores User Data in order to provide the Service to your enterprise and all of the Authorized Users in your enterprise. All User Data that you submit to the Service, including all email queries made by all Authorized Users, all responses from the Service, and all documents security and management data that is derived from the Service (such as rankings of topics discussed and the Service’s assessment of the expertise of particular Authorized Users), are included within User Data and are available to all Authorized Users within your Licensee’s enterprise.

Web Tracking Information: We use Web Tracking Information to administer the Service and to understand how well our Service is working, to store your user preferences, and to develop statistical information on usage of the Services. This allows us to determine which features visitors like best to help us improve our Service, to personalize your user experience, and to measure overall effectiveness.

Aggregate Information: We will also create statistical, aggregated data relating to our users and the Service for analytical purposes. Aggregated data is derived from Personal Information and User Data but in its aggregated form it does not duplicate or reveal any User Data or relate to or identify any individual. This data is used to understand our customer base and to develop, improve and market our services.

Legal Exception: Notwithstanding the above, we may in any event use Personal Information and other information collected through the Service to the extent required by law or legal process, to resolve disputes, to enforce our agreements (including this Privacy Policy and the Terms of Service) with you, or if in our reasonable discretion use is necessary to protect our legal rights or to protect third parties.

Email Communications: If you register and provide your email address, we will send you administrative and promotional emails. If you wish to opt out of promotional emails, you may do so by following the “unsubscribe” instructions in the email, or by editing your account settings as described below. All users receive administrative emails, and so you cannot opt out of them while you remain registered.

What Information Do We Disclose to Third Parties?

Personal Information and User Data: We will not disclose your Personal Information or User Data to any third parties except as follows:

(i) to third party contractors engaged to provide services on our behalf (“Contractors”), such as performing marketing, analyzing data and usage of the Service, hosting and operating the Service or providing support and maintenance services for the Service, or providing customer service. We enter into agreements with all Contractors that require Contractors to use the Personal Information they receive only to perform services for us.

(ii) when we have your consent to share the information.

Appsulate treats User Data as the confidential information of the Licensee enterprise, and does not provide User Data to any Authorized Users from other Licensee enterprises. In any event, all User Data will be disclosed or available to all Authorized Users within your Licensee enterprise.

Web Tracking Information: We disclose Web Tracking Information to Contractors, in order to analyze the performance of the Service and the behavior of users, and to operate and improve the Service.

Aggregate Information: We may disclose aggregated data that does not contain Personal Information or User Data to any third parties, such as potential customers, business partners, and funding sources, in order to describe our business and operations.

Network Operators: Use of the Service may involve use of the services of third party telecommunications carriers. Such carriers are not our contractors, and any information that a carrier collects in connection with your use of the Service is not “Personal Information” and is not subject to this Privacy Policy. We are not responsible for the acts or omissions of telecommunications carriers.

Additional Disclosures: We reserve the right to disclose any information we collect in connection with the Service, including Personal Information, (a) to any successor to our business as a result of any merger, acquisition, asset sale or similar transaction; and (b) to any law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights or to protect third parties.

Privacy Settings/Opt Out

If you would like your name and email address permanently removed from our database, please contact us at info@appsulate.com. We will promptly delete your name and email address and you will no longer receive email from Appsulate. Your removal from the mailing list or database will not remove User Data you have submitted to us or records of past use of the Service, nor delete information stored in our data backups and archives. User Data, including User Data submitted, data on past queries and data stored in backups and archives will be maintained and/or deleted in the ordinary course of Appsulate’s business. Appsulate does not provide copies of User Data to its customers.

General

Security: We use reasonable security precautions to protect the security and integrity of your Personal Information in accordance with this policy and applicable law. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.

Links: The Appsulate Service may contain links to other websites. Appsulate is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our Service and review the privacy statements of each third party website. This Privacy Policy applies solely to information collected by the Service.

Amendments: Appsulate may modify or amend this policy from time to time. If we make any material changes, as determined by Appsulate, in the way in which Personal Information is collected, used or transferred, we will notify you of these changes by modification of this Privacy Policy, which will be available for review by you at the Service. Notwithstanding any modifications we may make, any Personal Information collected by Appsulate from you will be treated in accordance with the privacy policy in effect at the time information was collected, unless we obtain your consent otherwise.

Children: Appsulate does not knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of the Service is directed at persons under 13. If you are under 13 years of age, then please do not use the Service. If Appsulate learns that personally identifiable information of persons less than 13 years of age has been collected without verifiable parental consent, then Appsulate will take the appropriate steps to delete this information. To make such a request, please contact us at info@appsulate.com.

Service Visitors from outside the United States: Appsulate and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. If you choose to access or use the Service, you consent to the use and disclosure of information in accordance with this privacy policy and subject to such laws.

Effective Date of this policy: October 1, 2017