Effective: November 6, 2018
Last updated: October, 2018
Scope and Purpose
1. The information we collect:
Information collected directly
We may collect personal information about you—such as your name, address, telephone number, fax number, e-mail address, etc.—directly from you. For example, personal information may be collected when you fill out a 'Contact Us' form, sign up for our mailing lists, submit information as part of certain online services, post comments on our blogs, or otherwise provide us information through the Sites. Generally, the information we collect includes your:
- Name, company name and title/position.
- Email address, phone number, mailing address and contact details.
- Contact preferences and interests.
- Business affiliations.
- Other information related to your request or inquiry.
We use log files, pixel tags, local storage objects and other tracking technologies to automatically collect information when users access or use the services or visit our Site, such as an IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider ("ISP"), referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information.
2. Our use of personal information
We use the personal information you provide to respond to your request or inquiry and in the ordinary course of conducting our business. Generally, we use the information (including personal information) that we collect online as follows:
Providing support and services
To provide and operate our Sites, communicate with you about your use of the Sites, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.
Responding to your requests
To respond to your inquiries, fulfill your orders and requests, and consider your request or application (eg, if you have submitted a resume or other application information online or by email, we will use it as part of the application review process).
To tailor content we may send or display on the Sites, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
Newsletters, mailing lists and direct marketing
For direct marketing purposes, including to send you newsletters, customer alerts and information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them.
Analytics and improvement
To better understand how users access and use the Sites, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop services and features.
Protect our legal rights and prevent misuse
Comply with legal obligations
To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court orders, and/or other lawful requests by regulators and/or law enforcement, including responding to national security or law enforcement disclosure requirements.
General business operations
Where necessary, for the administration of our general business, accounting, recordkeeping and legal functions.
Anonymous and de-identified information
We create and use anonymous and de-identified information to assess, improve and develop our business, products and services, and for similar research and analytics purposes.
3. Disclosure of personal information
We will not rent or sell your personal information, nor will we share it with third parties, outside of Elimu, for their marketing purposes. We may share personal information with the following categories of third parties:
Third party service providers that provide services to us or to whom we outsource certain services, such as data hosting or software or technology services.
- Our professional advisers, such as lawyers and accountants.
- Government and/or regulatory authorities.
- Professional indemnity insurers.
- Regulators, tax authorities and/or corporate registries.
In addition, we may disclose personal information to other third parties under the following circumstances:
- As part of any merger, sale and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law.
- If we are required to do so by law (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order).
- Where we believe it necessary to respond to claims asserted against us, comply with legal processes (eg, subpoenas or warrants), enforce or administer our agreements and terms, or for fraud prevention, risk assessment, investigation, and to protect the rights, property or safety of Elimu, our customers, or others.
We may also share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.
4. Cookies and similar devices
We and our service providers use log files and other mechanisms to gather information about your use of our Sites.
Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.
Third party analytics
Clear GIFs, pixel tags and other technologies
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our services to, among other things, track the activities of users of our services, help us manage content, and compile statistics about usage of our services. We and our third party service providers may also use clear GIFs in HTML emails to our customers, to help us track email response rates, to identify when our emails are viewed, and to track whether our emails are forwarded.
Our Site does not respond to do-not-track signals. For more information about do-not-track signals, please click here. You may, however, disable certain tracking as discussed above (eg, by disabling cookies).
5. Direct marketing
As noted, we may send periodic promotional emails to you, and where required by law, we will obtain your consent to do so. You may opt out of such communications at any time by following the opt-out instructions contained in the email or email us at firstname.lastname@example.org. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.
6. Access and correction
If you would like to review the personal information we have collected about you via the Sites, or request that we update or delete it, please contact us at email@example.com.
7. Third party websites and links
Our Site contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites' privacy notices as we have no control over information that is submitted to, or collected by, these third parties.
8. Our commitment to security
We employ security measures to prevent unauthorized access to information that we collect online. However, we cannot guarantee the security of your personal information.
9. How to contact us
We reserve the right to revise this Policy or any part of it from time to time. Please review the Policy periodically for changes. If we make material changes, we will endeavor to provide notice ahead of such changes, such as by email or through a notice on www.elimu.io .
11. GDPR Statement
For persons located in the EEA: The EU General Data Protection Regulation (“GDPR”) specifies the rights you have in relation to your personal data, and what companies that process your personal data are permitted and required to do. It also requires that we provide you with the following information in addition to that which you have already received.
The GDPR introduces new and extended rights in relation to your personal data beyond those already highlighted to you. These are:
- The right to rectify, or erase any wrong or incomplete personal data that Elimu holds about you;
- The right to access the personal data that Elimu holds about you;
- The right, in some cases, to object to the processing of your personal data on legitimate grounds;
- The right not to be subjected to automated decision making intended to evaluate certain personal aspects relating to you, such as analytics based on conduct. Please refer to the cookies section of the privacy notice for more information on how to exercise this right if it is indicated that cookies are being used;
- Where you have provided your personal data to us with your consent or as part of a contract, the right to the portability of that personal data to another person or, if it’s technically feasible for us to do so, to another company;
- The right to lodge a complaint with your national data protection supervisory authority or to receive compensation for any damage you suffer; and
- The right to withdraw your consent to Elimu’s processing of your personal data without detriment, where you have provided consent for Elimu to process your personal data.
To exercise these rights, please contact us at firstname.lastname@example.org.
Further Information You Need to Know
- International transfers - Elimu is based in the United States; when you submit personal information to us, or when others provide personal information to us, we will receive it and process it in the United States and in other locations where we have service providers. In order to provide services, we also may need to transfer your personal information to locations in other jurisdictions. Countries outside the EEA may not offer the same level of protection as required by the EEA. In order to safeguard your personal data we will only make such transfers on the basis of (i) a decision of the European Commission that permits this, or (ii) subject to EU-approved Standard Contractual Clauses. You have a right to obtain details of the mechanism under which your personal information is transferred outside of the EEA; you may request such details by contacting us as set forth in the "How to contact us" section above.
- Storage - Your personal data will be stored for as long as it is needed to provide you with (i) the Elimu service or product that you have requested; and/or (ii) access to our websites and services. Alternatively, your personal data will also be stored for as long as we require it to respond to your queries and concerns or in accordance with any legal requirements, including those in relation to product or medical device safety. For further information please contact us as set forth above.
- Why we need your data - The provision of personal data to Elimu is required to fulfill the terms of a contract you have with Elimu, to provide you with a product or service or information you have requested, to comply with local laws, such as those relating to product safety. Any failure to provide such personal data will mean that Elimu cannot provide you with the product or service or information you have requested.