Information We Collect
How we collect and store information depends on how you interact with us. You can use some of the Services without providing any information other than that automatically collected as described below (for example, if you browse the Services without registering or signing in). Several categories of information are collected from you, as described below.
INFORMATION YOU PROVIDE
We may collect information about you during your use of the Services, including your name, username, password, email address, phone number, other contact information, payment information, and other information you provide or post on our Services (such as your goals, job information and preferences) or allow us to access when you do certain things, such as:
- Register to use the Services;
- Request certain features (e.g., newsletters, updates, and other products);
- Connect with the Services or otherwise allow us to access certain information about you via a social media service (e.g., LinkedIn);
- Contact us with a question or for customer support;
- Enter a sweepstakes or contest or register for a promotion;
- Participate in voting or polling activities;
- Make a purchase; or
- Post user-generated content to or on any of our Services.
You have the right to access and modify your data through the profile you create on our Services as well as through a request to sent to the contact information provided below.
Please be careful and responsible whenever you are online. Certain portions of the Services may be open to any online viewer that you decide to share information with via a link, email, “share” function, or posting that you send or we send on your behalf with your permission. Should you choose to voluntarily disclose information through the Services, such as via social media service connections or our blogs, that information can be viewed publicly and can be collected and used by third parties without our knowledge and may result in unsolicited messages from other individuals or third parties. We are not responsible for any publication or use of any personal information you choose to post in these locations or share.
We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as (a) IP addresses, mobile device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, and the city, state and country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. As described further below, we may use third party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
Cookies and other electronic technologies.
Information from Third Parties
We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from or about you with information we obtain about you from such third parties or affiliates.
Anonymous or De-Identified Data
What we do with information we collect
We use the information that we collect for the following purposes:
- To deliver and support our products and services;
- To process and respond to your inquiries and provide you with customer service;
- To contact you with information that we believe will be of interest to you (such as product announcements, software updates, and special offers);
- To analyze the accuracy, effectiveness, usability, or popularity of the Services;
- To improve the content and features of the Services or develop new Services;
- To allow us to personalize the content and advertising that you see on the Services;
- To administer sweepstakes and contests;
- To enforce the legal terms that govern your use of the Services; and
- To administer and troubleshoot the Services.
How we share your information
- We have your explicit consent to share the information.
- We need to share your information to fulfill your product or service request, such as with a service provider who is working on our behalf.
- We wish to contact you with information about products and services from our business partners.
- We have a good faith belief that sharing or otherwise permitting access, disclosure, use or preservation of such information is reasonably necessary in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.
- We have a relationship with an affiliate or partner that you have an online or off-line relationship with, or have visited the affiliate or partner’s web site that links to or mentions the Everwise site, and have registered for Everwise online services through the partner’s or affiliate’s program or site.
- As we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
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.
In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US or Swiss-US Privacy Shield Frameworks, Everwise is potentially liable.
Online analytics & tailored advertising
We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology described in the Automatically-Collected Information section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on by clicking here.
How we secure your information
We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
The Services are not intended for persons under the age of 13. We require that only persons 13 years of age or older use the Services. By using the Services, you hereby represent that you are at least 13 years old. If we become aware of a user under the age of 13, we will make reasonable efforts to promptly delete that user’s information.
California do not track policy
We are committed to providing you with meaningful choices about the information collected on our Services for third party purposes, and that is why we provide above the NAI “Consumer Opt-out” link, DAA opt-out link, and Google opt-out link. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.
EU-US and Swiss-US Privacy Shield Framework
Everwise has further committed to refer unresolved privacy complaints under the Privacy Shield Principles through the 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 limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Everwise commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
Your communication choices
Your California privacy rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to email@example.com.
Federal Trade Commission
Everwise is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
SUPPLEMENTAL EU GDPR PRIVACY NOTICE
European Union Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“EU GDPR”), requires Everwise to provide additional and different information about its data processing practices to data subjects in the European Union (“EU”).
If you are located in a member state of the EU and access our Services or otherwise provide us with your personal data, this Supplemental EU GDPR Privacy Notice applies to you.
The Data Controller
If you are using our Services as a protege, the data controller is your employer. Everwise is a Data Processor on behalf of your employer with respect to your data uploaded to an account in our Services.
If you are using our Services as an Everwise mentor, the data controller is Everwise.
Our Legal Bases for Processing Personal Data
We process your personal data on several different legal bases, as follows:
Legitimate Interests: We process the personal data of users of our Services as necessary to pursue the following legitimate interests, pursuant to Article 6(1)(f) of the EU GDPR: To provide users with a good user experience, to maintain and secure our Services, to understand our users so that we can tailor our services to them, and to support and provide requested services and information to our users or customers. In these cases, we will ensure that your privacy and other fundamental interests do not override our legitimate interests.
Legal Obligations: If we are subject to a lawful access request, engaged in a legal proceeding or suspect a user of illegal conduct, we may need to process your personal data as necessary to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders, and legal process, pursuant to Article 6(1)(c) of the EU GDPR.
Consent: If we are required to obtain your consent to place certain cookies on your device or engage in other processing activities associated with the Services, we may perform such processing on the basis of your consent if you have provided it, pursuant to Article 6(1)(a) of the EU GDPR. In such cases, you may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. In such cases, providing your consent is voluntary, but we will not be able to provide you with a service for which we require your consent until we obtain such consent.
Vital Interests: In extenuating circumstances, we may need to process your personal data to protect the vital interests of you or another natural person, pursuant to Article 6(1)(d) of the EU GDPR.
Transferring and Protecting Personal Data
We disclose your personal data to recipients in the following jurisdiction or jurisdictions outside of the EU which do not provide adequate protection to personal data according to the European Commission: the United States of America. By entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in Article 46(5) of the EU GDPR or other adequate means, we have established that all such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer (including to our Affiliates outside the EU) is subject to appropriate onward transfer requirements as required by the applicable contract or applicable law. You can ask for a copy of such appropriate data transfer agreements by contacting firstname.lastname@example.org
Your Data Subject Rights
Under the conditions set out under the EU GDPR and any other national data protection laws in the EU, you have the following rights:
- Right of access: You have the right to obtain from us confirmation as to whether your personal data is being processed, and, where that is the case, to request access to the personal data. The access information includes, among other things, the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. You have the right to obtain a copy of the personal data undergoing processing. Subject to applicable law, we may charge a reasonable fee for copies, based on administrative costs.
- Right to rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- Right to erasure: You have the right to ask us to erase your personal data to the extent it is not required for legally required purposes.
- Right to restriction of processing: You have the right to request restriction of processing of your personal data, in which case, it would be marked and processed by us only for certain purposes.
- Right to data portability: You have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit the personal data to another entity without hindrance from us.
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. Exercising this right will not incur any cost. Such a right to object may not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
- Right to Submit Complaints: You have a right to lodge a complaint with a supervisory authority.
Please note that these rights may be limited under the applicable national data protection law. To exercise your rights please contact us at email@example.com.
Retainment of Your Personal Data
If you register for an account on our Services, we retain your personal data for as long as you have an account with us. Upon your request, we will delete or erase your personal data within one month after your personal data is no longer necessary for us to provide you with any information or services you have requested, pursue any of the legitimate interests specified herein where the legitimate interest is not overridden by your fundamental rights or privacy interests, comply with any legal obligations to which we are subject, or defend any legal claim against us or support any legal claim made by us, including any potential appeal.
Requirement to Provide Personal Data
In order to create an account with Everwise and to use our Services, you need to provide us with your name, email address, and professional development goals. In order to use our Services, you must consent to cookies that are strictly necessary.
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