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Last Revised as of: June 24, 2024
Your privacy is important to Eagle Point Software Corporation (“Eagle Point”, “we”, “our”, “us”). This Eagle Point Privacy Policy (our “Privacy Policy”) tells you about how we collect, use, disclose, transfer, and store your information, as well as the choices you have regarding your information. It also gives you information about our marketing and advertising practices and offline activities. Our primary goal is to provide you with information about:
Eagle Point’s Privacy Policy applies to Eagle Point websites and applications that include a link or reference to this Privacy Policy as well as information about you that we collect offline. It does not apply to sites, services, and products that do not reference, display or link to this Privacy Policy, or that have their own privacy policies or statements.
Eagle Point collects, uses, and transfers information from and about you to provide you with the best experiences with our products and services; to improve and secure our products and services; to respond to your inquiries and contact you regarding our products and services; to manage your relationship with us; to best serve your interests by customizing your experience and interactions with Eagle Point; and for the other purposes described in this Privacy Policy. The type of information Eagle Point may collect from or about you includes:
Information including your name, email address, postal address, phone number, and similar contact information when you create a user ID to access our websites or applications, create a user profile, register for an event or other offering, make a purchase, or contact us for services, support or other reasons.
Username, security and authentication credentials including security questions and answers, and any unique ID number used to identify you and your associated information.
Demographic information, such as your profile picture, language preference, ZIP code, office, business unit, country, preferences, interests, and other similar things.
Information associated with your purchases such as your contact information including billing address, as well as the types of software that you use. We use a third-party payment processor and do not receive credit-card or other financial information.
Information collected automatically when you communicate with us, access our websites and servers through a browser, application, or other client. This includes data about your visit, including the pages you view, the links you click, and other actions taken in connection with our websites and services. We also collect certain standard information that your browser sends to every website you visit, such as your IP address, browser type and language, operating system, access times, and referring website addresses. When you receive newsletters or promotional email from Eagle Point, we may use Web beacons, customized links, or similar technologies to determine whether the email has been opened and which links you click in order to provide you more focused email communications or other information in the future.
We require you to log-in when you activate and use our software and products, including our cloud services. We monitor and collect certain usage information. For example, we track your device, products, features and content you are using, and other usage data such as the date and time of use.
We receive and collect your information if you make a purchase through our channel partners or ecommerce providers.
To keep our databases accurate and current, we may combine information you give us with information from public sources and trustworthy companies. For example, we may use services from other companies to ensure that we have accurate contact information and to tell us your geographic area based on your IP address so that we can provide you with more relevant content and offerings.
When you contact us to request services, support or other information, we may keep a record of the communication and your contact information.
We collect data about your location when you enable location-based services or features such as location derived from your IP address or data.
Eagle Point stores the information we collect from and about you in the United States and/or the United Kingdom, regardless of where you reside or where the information originates. This information is accessed by Eagle Point affiliates, employees, contractors, business partners and service providers located throughout the world only as necessary for the purposes described in this Privacy Policy. If you are in the European Union, United Kingdom, Switzerland, or another region with laws governing data collection, transfer, and use, you agree and consent to the transfer to, and processing and use of, your information in the United States and other countries where privacy laws may be considered less strict than those of your jurisdiction. Providing us with information or continuing to use our sites and services indicates that you are agreeing and consenting to the collection, use, disclosure, management, and storage of information collected from you as described in this Privacy Policy.
Eagle Point uses the information we collect from and about you in several useful ways, including:
You may manage your preferences on how you receive marketing communications by contacting us.
We do not sell or otherwise disclose information we collect to others except as described in this Privacy Policy. Eagle Point may share your information we collect with our affiliates.
In some cases, Eagle Point may share information we collect with vendors or agents working on our behalf for any purposes described in in this Privacy Policy. For example, we may share information for purposes of data processing or storage, delivering customer support, processing credit card payments, and sending emails on our behalf. In such cases, these companies will be permitted to obtain only the information they need to deliver the respective services and are not allowed to use your information for any other purpose, except where required by law. Such vendors, business partners and agents must abide by our data privacy and security requirements and they are required to maintain the confidentiality of the information, except where required by law to disclose your information.
Eagle Point may also share information with carefully selected strategic partners who provide services and sponsor events that may be of interest to you. These companies are obligated to protect your information and use it in accordance with their own privacy policies and practices. Here is a list of links to the Privacy Policies of strategic partners that work on our behalf:
Some Eagle Point webpages allow you to choose to share your information with select Eagle Point partners so that they can contact you about their products, services, or offers. Other webpages do not share your contact information with third parties for marketing purposes, but instead may give you a choice as to whether you wish to receive communications from Eagle Point on behalf of external business partners about a partner’s particular offering (without transferring your information to the third party).
Some Eagle Point services may be co-branded and offered in conjunction with another company. If you register for or use such services, both Eagle Point and the other company may receive information collected in connection with the co-branded services. The other company’s use of your information is subject to such other company’s own privacy policies and practices, and Eagle Point is not responsible for the privacy practices of, or use of your information by, such other companies.
We may access and/or disclose information we collect if we believe such action is necessary to: (a) comply with the law or legal process served on Eagle Point; (b) protect and defend the rights or property of Eagle Point (including the enforcement of our agreements) or third parties; or (c) act in urgent circumstances to protect the personal safety of users of Eagle Point services or members of the public. If we merge with another company or reorganize some part or all of our business, assets, or stock (including if we file for bankruptcy or similar proceeding), we may share information we collect from and about you in connection with the merger or reorganization. You acknowledge that such transfers may occur, and that any acquirer may continue to use information we collect from and about you as set forth in this Privacy Policy.
You may have the ability to view or edit information we collect from and about you online. To help prevent this information from being viewed by others, you will be required to sign in with your credentials (e.g. username and password). The appropriate method(s) for accessing your information will depend on which sites or services you have used. Some Eagle Point webpages or services may collect information that you may be able to access through alternative means of access described by the service. Or you can use our contact us link and we will contact you within 30 days regarding your request.
You can stop the delivery of future promotional email from Eagle Point and services by following the specific instructions set forth in such promotional email. You may also have the option of proactively making choices about the communications you receive from Eagle Point by contacting us. However, we may send out emails periodically informing you of administrative and technical service issues about the products and services that you are using. These communications are considered essential to the provision of the service you have requested. You will not be able to choose to unsubscribe to these mailings, as they are considered a part of the service you have chosen.
When you are using or accessing our websites and our products and services, our collection, storage, processing and transfer of your information as described in this Privacy Policy may result in our acting as a processor on your behalf and we may accordingly be deemed a “data processor” as defined in the General Data Protection Regulation (GDPR). Our headquarters is in the United States, and we operate there as well as in other countries, either through our affiliates or through third parties. Therefore, we, ourselves or via third parties, may transfer your personal information to, or process or gain access to it from, jurisdictions that may not provide the same level of protections as your home jurisdiction. We are relying on the derogations in Article 49 of the GDPR, as the United States has not received a designation of adequacy under Article 45 of the GDPR. Therefore, it is important to note that we may transfer your personal data to the United States only (a) with your explicit informed consent, (b) for contractual necessity (which means that the processing of your personal information is required for us to provide services to you), or (c) for other reasons enumerated in Article 49, including:
Under the GDPR, you have eight rights:
Your use of our websites and of our products and services does not require us to collect or store any sensitive data (under the GDPR) about you and we employ a variety of safeguards to help to secure and maintain the privacy of your personal data. To that end, to comply with the GDPR, our form of Data Processing Addendum (found at www.eaglepoint.com/dpa) forms a part of and is incorporated within our Terms and Conditions where applicable.
Eagle Point complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Eagle Point has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Eagle Point has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Eagle Point commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to the International Centre for Dispute Resolution, the international division of the American Arbitration Association (“ICDR-AAA”), an alternative dispute resolution provider based in the United States and Singapore. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of ICDR-AAA are provided at no cost to you.
In addition, Eagle Point is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided that you have invoked binding arbitration by delivering notice to us and following the procedures set forth in Annex I of the DPF Principles, subject to the conditions set forth therein.
Eagle Point’s participation in the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss – U.S. DPF is subject to investigation and enforcement by the Federal Trade Commission. Eagle Point remains liable under the DPF Principles if an agent processes personal data covered by this Privacy Policy in a manner inconsistent with the DPF Principles, except where it is not responsible for the event giving rise to the damage.
Eagle Point agrees to periodically review and verify its compliance with the DPF Principles and to remedy any issues arising out of its failure to comply with them.
We and our approved partners use cookies and similar technologies on our websites, services, applications, tools and electronic communications (collectively referred to as our “sites and services”) that automatically receive and track certain data about your device and interaction with our sites and services.
“Cookies” are small text files that are stored on your browser or device by websites. There are different types of cookies. Cookies served by the entity that operates the website or app you are visiting or using are called “first-party cookies” (for example, cookies served by Eagle Point while you are using our sites and services are first-party cookies). Cookies served by companies that are not operating the website or app you are visiting or using are called “third-party cookies” (for example, we may allow an analytics partner to set a cookie on your computer via our website while you visit our website, and that would be a third-party cookie). Cookies may also endure for different periods of time. “Session cookies” only last as long as your browser or app is open. These are deleted automatically once you close your browser or app. Other cookies are “persistent cookies” meaning that they survive after your browser or app is closed (for example, they may recognize your computer when you re-open our sites and services).
“Pixel tags” (also called Web beacons, clear GIFs or action tags) are small blocks of code installed on (or called by) a webpage, app or advertisement, which can retrieve certain information about your device and browser, including device type, operating system, browser type and version, website visited, time of visit, referring website, IP address, and other similar information (including the small text file (the cookie) that uniquely identifies the device). Pixels provide the means by which third parties can set and read browser cookies from a domain that they do not themselves operate and collect information about visitors to that domain, typically with the permission of the domain owner. “Software Development Kits” (also called SDKs) function like pixels and cookies but operate in the mobile app context where pixels and cookies cannot always function. The primary app developer can install pieces of code (the SDK) from partners in the app, and thereby allow the partner to collect certain information about user interaction with the app, information about the user device and network information.
“Local storage” refers generally to other places on a browser or device where information can be stored by websites, ads or third parties (such as HTML5 local storage, Flash cookie storage and browser cache).
In this Privacy Policy, these and similar technologies are collectively referred to as “cookies and similar technologies.”
These cookies and similar technologies receive and track certain data about your device (such as your device type, operating system, device IP address, mobile network carrier, and anonymous device and advertising identifiers) and interaction with our sites and services (such as access dates and times, features or pages viewed, advertisements and ad features viewed, and approximate location based on your IP address).
If you have provided us with any information that may identify you (for example, through a registration or a request for certain materials), we may associate this identifiable information with information gathered through these cookies and similar technologies. This allows us to offer increased personalization and functionality.
The following table sets out the different categories of cookies and similar technologies that our sites and services use and why we use them
Operationally Necessary
These cookies and similar technologies are necessary to the operation of our sites and services. This includes technologies that (i) allow you access to our sites and services, (ii) are required to identify irregular behavior on our sites and services, prevent fraudulent activity and improve security, or (iii) that allow you to make use of our functions such as shopping carts or similar functions.
Functionality
These first- and third-party cookies and similar technologies allow us to offer you enhanced functionality when accessing or using our sites and services. This may include identifying you when you sign into our sites and services or keeping track of your specified preferences, interests, or past items viewed or utilized so that we may enhance the presentation of content on our sites and services. These cookies and similar technologies also help us provide you and others with social plug-ins (for example, Facebook, YouTube, LinkedIn) and other customized content and experiences.
Performance, Analytics and Research
These first- and third-party cookies and similar technologies allow us to assess, improve and research the performance and use of our sites and services, uncover and resolve issues with our sites and services, better understand the interests of people who interact with our sites and services, and track advertisement campaign performance and efficiency. This includes our analytics activities that help us understand how our visitors use our sites and services, determine if you have interacted with our content, messaging or ads or whether you have viewed an advertisement or link, or to improve the content of our sites and services.
For example, our websites may use the following third-party analytics tools:
Advertising and Targeting
These first- and third-party cookies and similar technologies are used to deliver relevant ads. For example, we and our approved ad partners may rely on information gleaned through these cookies and similar technologies to serve you ads that may be interesting to you on other websites and apps. Similarly, our partners may use a cookie or other technology to group users that share a common interest into audience segments and to deliver advertisements and offers that may be of interest to users within a given segment. One way we do so is by allowing network advertising companies with whom we work to place their own cookies when an individual visits our sites and services. This enables the network advertising company to recognize individuals who have previously visited our sites and services. When the individual visits a third-party website on which that network advertising company has purchased ad space, the advertising company can then recognize the individual’s interest in our products and services and deliver one of our advertisements.
For example, some of our sites and services may use Facebook Custom Audiences to provide advertisements about our goods and services that may be of interest to you on Facebook. If you would like to opt-out of having your data used by these cookies, please use the opt-out available here.
For more information about interest-based ads, or to opt out of having your web-browsing information used for targeting and behavioral advertising purposes by those network advertising companies that honor such requests, please visit: www.aboutads.info/choices (if you are in the United States) or http://youronlinechoices.eu/ (if you are in Europe).
Most Web browsers are set to accept cookies by default. However, in addition to the specific opt-out mechanisms described above, you can typically choose to set your browser to remove or reject browser cookies. To do so, please follow the instructions provided by your browser, which are usually located within the “Help” or “Preferences” menu. Removing or rejecting browser cookies does not necessarily affect third-party Flash cookies (see “Local storage” above) which may be used by us or our partners in connection with our sites and services. To delete or disable Flash cookies, please visit this site for more information. For further information about cookies and similar technologies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit www.allaboutcookies.org and www.youronlinechoices.eu.
Some Web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Our sites and services do not currently respond to these “do-not-track” signals.
SECURITY OF YOUR INFORMATION
Eagle Point is committed to protecting the security of information we collect from and about you. We use a variety of security technologies and procedures to help protect this information from unauthorized access, use, or disclosure. For example, we store the information you provide on computer systems with limited access, which are located in controlled facilities. When we transmit highly confidential information (such as a credit card number or password) over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol. If a password is used to help protect your accounts and information, it is your responsibility to keep your password confidential. Do not share this information with anyone. If you are sharing a computer with anyone you should always choose to log out before leaving a site or service to protect access to your information from subsequent users.
COLLECTION AND USE OF CHILDREN’S INFORMATION
Eagle Point webpages and services are intended for business audiences and we do not knowingly collect any personal information from children. When an Eagle Point webpage does collect age information, and users identify themselves as under 13, the site will either block such users from providing personal information, or will seek to obtain consent from parents for the collection, use, and sharing of their children’s personal information. We will not knowingly ask children under the age of 13 to provide personal information to us. Eagle Point strongly encourages you to talk with your children about communicating with strangers and disclosing personal information online and about using the Internet safely.
USE OF COOKIES
We and our approved partners use cookies and similar technologies on our websites, services, applications, tools, and electronic communications (collectively referred to as our “sites and services”) that automatically receive and track certain data about your device and interaction with our sites and services. You can read more above about the types of cookies and similar technologies we use, why we use them, and how you can exercise your choices.
LINKS TO OTHER SITES
Eagle Point webpages may contain links to other sites. Eagle Point is not responsible for the privacy practices or the content of other websites. Please refer to the policies of the respective site.
ENFORCEMENT OF THIS PRIVACY POLICY
If you have questions regarding this Privacy Policy, you should contact us by clicking on this contact us link.
EUROPEAN REPRESENTATIVE
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Eagle Point Software Corporation has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by using EDPO’s https://edpo.com/gdpr-data-request/, or writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.
UK REPRESENTATIVE
Pursuant to the UK GDPR, Eagle Point Software Corporation has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR by using EDPO UK’s online request form https://edpo.com/uk-gdpr-data-request/ or by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.
CHANGES TO THIS PRIVACY POLICY
We will update this Privacy Policy when necessary to reflect customer feedback and changes in our services and practices. When we make changes, we will post the “Last Revised” date at the top of this Privacy Policy so you know when those changes were made. If there are material changes to this Privacy Policy or in how Eagle Point will use information we collect from and about you, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification. We encourage you to periodically review this Privacy Policy to be informed of how Eagle Point is protecting your information.
CONTACTING US
Eagle Point welcomes your comments regarding this Privacy Policy. If you have questions about this Privacy Policy, or believe that we have not adhered to it, please contact us by clicking on this contact us link.
