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Legal Bases for Processing-EEA
For individuals from the European Economic Area (“EEA”), the requirements of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) shall apply. PrimeRevenue, Inc., as the controller, collects and processes information about you only where it has a legal basis for doing so under the GDPR, as further described below.
The legal basis for the collection and processing of the personal information will depend on the type of information collected and the context in which it has been provided. PrimeRevenue collects and processes your personal information where:
- It satisfies a legitimate interest which is not overridden by your data protection interests or your fundamental rights and freedoms;
- It is necessary to provide the services to you and your company, provide customer support, and protect the security of the Sites;
- You provide your consent for a specific purpose; or
- It is necessary to comply with a legal obligation.
Your personal information will be retained for as long as necessary to provide the Services to your company and to other third parties with legitimate business interests in such information, in order for PrimeRevenue and other controllers to comply with applicable laws and enforce relevant legal agreements.
International Transfers; EU-U.S. and Swiss Privacy Shield
PrimeRevenue remains accountable for personal information that it receives under the Privacy Shield and any subsequent transfers to a third party as described in the Privacy Shield Principles. PrimeRevenue remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal information on its behalf do so in a manner inconsistent with the Principles, unless PrimeRevenue proves that it is not responsible for the event giving rise to the damage.
PrimeRevenue’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
PrimeRevenue may be compelled to disclose personal information in response to lawful requests by public authorities, including for purposes of national security or law enforcement.
Information We Collect On the Sites and How We Use It
We collect and use personal and corporate information in the specific ways listed below:
Personal Data Collected for Legitimate Business Interest
User Accounts. If you are a user of the PrimeRevenue OpenSCi® platform and have received log-in instructions from PrimeRevenue’s customer support or sales teams for use of the password-protected portion of the Sites, you may use those instructions to log in. Upon log-in, you may be asked to register, and following the prompts, supply your name, company name, title, office location, email address and phone number (hereafter, “Contact Information”). This Contact Information is used to communicate with you and to carry out actions you request on the Sites, such as requests for support, and to track the transactions that are performed on a Site.
In connection with registration on a Site, PrimeRevenue collects other information, such as your IP address, which may be considered personal information in some jurisdictions. This information is used for purposes of validation, verification of a user account, tracking of transactions that you perform on a Site, security of the Site and other purposes.
Webinar Registration. Users may register directly on the Sites for PrimeRevenue webinars or other training services in order to receive specialized training in the functionality of the PrimeRevenue OpenSCi® systems and Services, and education on related topics. Those registering for these webinars are required to provide their Contact Information, which is used to register for the webinars and to communicate with you about these and related offerings.
Information Requests and Feedback. The Sites contain various user interfaces to allow visitors to the Sites to request more information about our products and Services, to use the functionalities of the Sites, or to provide us feedback about them. Contact Information is requested in each case, along with information about your computing environment and/or industry, and details of your request or reported feedback. This information is used in order to allow us to respond to your requests, to assure that our software and Services work correctly with your computing environment, to better understand our users’ needs or your specific issue, and to communicate with you about your requests and feedback, and to execute on the actions that you request via the various functions on the Sites.
Web Logs. Like most standard website servers, we may log IP addresses (a unique number assigned to every computer on the Internet) in order to improve security, analyze trends, administer the Sites, and perform the Services. We may track your movement within the Sites, the pages from which you were referred, access times and browser types. This information may include the browser you are using, the internet address from which you linked to our Sites, the unique IP address of the computer you used to access our Sites, your geographic location, and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness of our Sites, analyze trends, track user movement in the aggregate, and gather broad demographic information. We may also use personal and corporate information we collect through web logs to send you targeted offers and other communications.
Cookies. As a security measure, and to help make sure you receive information that is relevant to you, our Sites uses data “cookies.” Cookies are small text files that are stored on a user’s computer that identify a specific user the next time they access the Sites.
Web Beacons and Pixel Tags. Our web pages and emails may contain “web beacons” or “pixel tags.” Web beacons and pixel tags allow us to track receipt of an email, count users that have visited a web page or opened an email that contains a web beacon and collect other types of aggregate information. Using this information, we are able to measure the effectiveness of our content and how visitors use our Sites. This allows us to learn what pages are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of offers our registered users like to see. Some of the web beacons that are in place on our Sites are used only by us, and other web beacons are from our service providers who use this data to assist us in analyzing how our Sites are used. Once you provide Contact Information to us after clicking on an email that contains a web beacon, your Contact Information may subsequently be cross-referenced to the source email and the relevant web beacon or pixel tag information.
General Uses. We use your personal information in ways consistent with the reason for which you provide it to us, and for other legitimate business purposes, including in order to: (i) verify your identity, (ii) help us improve our products and services and develop and market new products and services, (iii) carry out the transaction, activity or request made by you on the Sites, (iv) investigate or settle inquiries or disputes, (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator, (vi) enforce our agreements with your company, (vii) protect the rights, property or safety of us or third parties, including other users of the Sites, (viii) provide support and network and information security for the Services, (ix) to detect, prevent, mitigate and investigate fraud or illegal activities and monitor suspicious activity, and (x) as otherwise required or permitted by law.
Personal Data Collected Based on Consent
Surveys. Surveys may appear on the Sites or via email, and in such case, with your consent, we will collect Contact Information from the participants in the survey. This information will be used to administer the survey, to analyze its results and for other specific purposes, which are disclosed at the time of collection. Survey responses will be aggregated and depersonalized before survey results are shared with any third parties.
Email Communications. Submission of your email address on the Sites will result in your being added to our mailing list for purposes of product updates, promotional and marketing messages and other communications, until such time as you opt out and withdraw your consent. In some of our email messages, we use a “click-through URL” linked to certain websites administered by or on behalf of PrimeRevenue. PrimeRevenue may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications. If you prefer not to be tracked in this way, you should not click on text or graphic links in the email messages. See below under “Choices and Opt-Out” to understand how you may control use of your Contact Information.
This section may be superseded or supplemented with regard to transactional data collected via use of the Services by the terms of any definitive agreement that your company has previously signed with PrimeRevenue governing your use of the Sites and the Services.
Choices and Opt-Out
PrimeRevenue communicates with its users by means of emails containing service-related messages and/or promotional and marketing information and materials.
As it relates to promotional and marketing messages, you can choose not to receive such promotional and marketing messages from PrimeRevenue in the future by either following the “unsubscribe” instructions located near the bottom of each marketing email, or by emailing us at PrimeRevenue at firstname.lastname@example.org or sending postal mail to the following address:
600 Peachtree Street, Suite 4400
Atlanta, GA 30308
As it relates to service-related messages, you can choose not to receive service-related messages from PrimeRevenue in the future by emailing us at PrimeRevenue at email@example.com or sending postal mail to the above address.
Please note, changes may not be effective immediately but will be made as provided under applicable law.
In addition, please note that an email address is a required field in order for your company to use the PrimeRevenue Sites and opting out will result in your company’s inability to use the PrimeRevenue Services. Should you desire to remove your email address from PrimeRevenue Sites, you can inform us by emailing us at PrimeRevenue at firstname.lastname@example.org. To continue using the PrimeRevenue Services, your company will need to provide another user email address.
Accessing and Controlling Your Personal Information
If you are from the EEA and have provided consent to use your personal information for a specific purpose, you have the right to withdraw your consent. Any withdrawal does not affect any processing that has already occurred. Where PrimeRevenue or a third party has a legitimate interest in using your personal information, you have the right to object to that use, but this means that you can no longer log on to the Sites. In this situation, your company will be required to provide contact information for another user to continue using the PrimeRevenue Services. If you have a statutory right to request erasure of your personal information, PrimeRevenue will honor that request, subject to any requirement to retain that personal information in accordance with applicable laws, statutes and regulations. With respect to personal information, we may share with other third parties, we provide customers and service providers located in the EEA, the UK, and Switzerland with an opportunity to opt-out of such sharing. Please email us at email@example.com (with a copy to firstname.lastname@example.org) if you would like to opt-out.
How We Share Your Personal Information
We do not share your personal information collected on the Sites with third parties without your permission, except as set forth herein, or as otherwise necessary or appropriate to (i) carry out the transaction, activity or request made by you on the Sites, (ii) comply with any applicable law, court order, other judicial process, or the requirements of a regulator, (iii) enforce our agreements with your company, (iv) protect the rights, property or safety of us or third parties, including other users of the Sites, (v) perform investigative security analysis on the Sites, or (vi) as otherwise required or permitted by law. This section may be superseded or supplemented with regard to transactional data collected via use of the Services by the terms of any definitive agreement that your company has previously signed with PrimeRevenue governing your use of the Sites and the Services.
We may collect and share aggregate website statistical information (such as downloads, survey results, traffic patterns or related information) with third parties.
Finally, we may hire contractors to provide certain services on our behalf, including information processing and storage, site hosting, database maintenance, electronic marketing, data analysis, or other services. These contractors are required to maintain the confidentiality of information they receive from us and are restricted from using the information for any purposes other than those authorized by us.
The Sites are not intended for or directed to persons less than 13 years of age. We do not knowingly solicit or collect personal information from children, and we do not knowingly market our services to children. If you are under 13 years of age, do not use the Sites.
The Sites have reasonable technical and organizational measures in place to protect against unauthorized or unlawful processing and against the accidental loss, destruction or damage of the information under our control. When you submit sensitive information via our Sites, such as support requests, that information is protected by physical, electronic and managerial procedures to secure the information that we collect via the Sites, including secure sockets layer (SSL) encryption technology. However, no data or email transmission over the Internet can be guaranteed as 100% secure or error free. As a result, while we strive to protect your personal information during transmission, we cannot ensure or warrant the security of any information you transmit to us or receive from us. We urge you to take steps to keep your personal information safe (including your account password), log out of your account after each use, and close your web browser.
The Sites may contain links and interactive functionality interacting with the websites of third parties. We are not responsible for and have no liability for the functionality, actions, inactions, privacy settings, privacy policies and content of any such website. Before enabling the sharing functions of the Sites to communicate with any such website, we strongly recommend that you review and understand the privacy policies, settings and information sharing functions of each such third party website. The links and interactive functionality for third party sites on the Sites in no way constitute an endorsement by PrimeRevenue of these third party websites.
Suggestions, materials or other intellectual property sent or transmitted to us via our Sites, including all feedback regarding the Sites, are governed by the separate terms applicable to such materials identified at the time of submission (if any). If no such terms are identified, all right, title and interest to all such materials and information shall belong to PrimeRevenue. All such items shall be deemed to be non-confidential, and we shall have no obligation of any kind with respect to such items and shall be free to use and distribute them to others without limitation, including, but not limited to developing and marketing products incorporating them.
If you have any concerns about the privacy practices of the Sites, please contact us at following address with a detailed description, and we will try to resolve it:
Attention: Chief Legal Officer
600 Peachtree Street, Suite 4400
Atlanta, GA 30308
Effective Date: March 12, 2021
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