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Privacy Policy

 

 

Privacy Policy

Last updated 05/25/2018

Privacy and online safety are important to us. We offer a software platform and mobile applications supporting the Human Resource function of businesses. We collect data about businesses and their employees (“Data”) when they use the platform, the applications, and our websites (collectively, “Services”). This privacy policy describes how we collect, use and disclose Data.

In this privacy policy, we sometimes refer to “You”. “You” may be a visitor to one of our websites, a user of one or more of our Services (“User”), or an employee of a User (“Employee”). We’ll do our best to clarify who we are referring to at various points in the policy. This policy does not apply to third-party websites, products, or services even if they link to our Services, and You should consider the privacy practices of those third-parties carefully. If You disagree with the practices described in this policy, You should (a) take the necessary steps to remove cookies from Your computer after leaving our website, and (b) discontinue Your use of our Services.

Overview

The Data we collect depends on how our Services are used. Usually, we receive Data directly, such as when a Snapeval or Spotlight account is created, test and live transactions are submitted through our platform, applications or website, or we receive an email. Other times, we get Data by recording interactions with our Services by, for example, using technologies like cookies. We may also get Data from third parties, like our financial partners or credit card processing providers.

The collection and use of data from a variety of sources is essential to our ability to provide our Services – and to help keep the Services safe. Data is critical in helping us to provide effective Services and increase the safety of Your experience with our Services.

Data We Collect

  1. Personal Data. We call Data that identifies, or that could reasonably be used to identify, You as an individual as “Personal Data”. We collect Personal Data in different ways. For example, we collect Personal Data when an individual or business registers for a Snapeval or Spotlight account, a User or Employee makes an entry using our Services or a User contacts us through our website or other means. We also receive Personal Data from other sources, such as our partners, financial service providers, credit card processors and publicly available sources. Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. The Personal Data that we may collect includes:
  • Contact details, such as name, postal address, telephone number, email address;
  • Transaction Data, such as credit or debit card number; and
  • Other Personal Data, in very limited cases, we may collect SSN or EIN.
  1. Other Data. We call Data other than Personal Data “Other Data”. We collect Other Data through a variety of sources. One of our sources for Other Data is cookies and other technologies that record Data about the use of our websites and the use of our Services generally. Other Data that we may collect include:
  • Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the version of the Services You are using;
  • Transaction data, such as purchases, purchase amount, date of purchase, and payment method;
  • Cookie and tracking technology data, such as time spent on the Services, pages visited, language preferences, and other anonymous traffic data; and
  • Company data, such as a company’s legal structure, product and service offerings, jurisdiction, and company records publicly available or shared with us for a business purpose.

How We Use Data

  1. Personal Data. We and our service providers use Personal Data to: (i) provide the Services; (ii) detect and prevent fraud; and (iii) promote, analyze and improve our products, systems, and tools. Examples of how we may use Personal Data include:
  • To verify an identity for compliance purposes;
  • To conduct manual or systematic monitoring for fraud and other harmful activity;
  • To respond to inquiries, send service notices and provide customer support;
  • To process a payment or provide related customer service;
  • For audits, regulatory purposes, and compliance with industry standards;
  • To develop new products;
  • To send marketing communications;
  • To improve or modify our Services; and
  • To conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business.
  1. Other Data. We may use Other Data for a range of different purposes, provided we comply with applicable law and our contractual commitments. In some countries (for example, European Economic Area countries), local legal regimes may require us to treat some or all of Other Data as “personal data” under applicable data protection laws. Where this is the case, we will process Other Data only for the same purposes as Personal Data under this privacy policy.

How We Disclose Data.

Snapeval, LLC does not sell or rent Personal Data to marketers or unaffiliated third parties. We share Your Personal Data with trusted third parties, including:

  1. To Our Service Providers. We share Data with service providers who help us provide the Services. Service providers help us with things like payment processing (i.e., payment method providers), website hosting, data analysis, information technology and related infrastructure, customer service, and email delivery;
  2. To Our Users. We share Data with Users as necessary to provide the Services;
  3. To Authorized Third Parties. We share data with parties directly authorized by a User to receive Data, such as payment processors. The use of Data by an authorized third party is subject to the third party’s privacy policy;
  4. To Third Parties. We will share Data with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
  5. Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside Your country of residence.

Advertising.

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to You when You access our websites, based on Data relating to Your access to and use of our websites on any of Your devices, as well as Data received from third parties. To do so, these companies may place or recognize a unique cookie, or similar tracking technology, on Your browser (including the use of pixel tags). They may also use these technologies, along with data they collect about Your online use, to recognize You across the devices You use, such as a mobile phone and a laptop, and to make decisions about the advertisements You see. If You would like more information about this practice, and to learn how to opt out of behavioral advertising delivered by Network Advertising Initiative member companies in desktop and mobile browsers on the particular device on which You are accessing this Privacy Policy, please visit the Network Advertising Initiative and Digital Advertising Alliance.

You may download the AppChoices app to opt out in mobile apps. In order to understand and improve the effectiveness of our advertising, we may also use web beacons, cookies, and other technologies to identify the fact that You have visited our website or seen one of our advertisements, and we may provide that Data to one or more third party advertising networks. The Data we provide may include the time and date of Your visit to our website, pages viewed, links clicked and other information that does not disclose Your ‘real world’ identity. Those advertising networks may recognize the web beacon or cookie associated with Your visit to our website when You visit other websites on which they serve advertising, and they may make decisions about the advertisements You see based on it. We may choose to work with Google AdWords, Doubleclick, AdRoll or other advertising networks. Each of these companies has its own privacy policy, which we encourage You to review. For more information about advertising and tracking online, visit the Network Advertising Initiative. This website allows consumers to “opt out” of the behavioral advertising delivered by member companies. To learn more about the cookies that may be served through our Services. At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.

Choice and Access.

You have choices regarding our use and disclosure of Your Personal Data:

  1. Opting out of receiving electronic communications from us. If You no longer want to receive marketing-related emails from us on a going-forward basis, You may opt-out via the unsubscribe link included in such emails. We will try to comply with Your request(s) as soon as reasonably practicable. Please note that if You opt-out of receiving marketing-related emails from us, we may still send You important administrative messages that are required to provide You with our Services.
  2. How You can access or change Your Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to the Services or by contacting privacy@snapeval.com.

If emailing us Your request, please make clear in the email what Personal Data You would like to review or have changed. For Your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that You use to send us Your request, and we may need to verify Your identity before implementing Your request.

Third-Party Payment Processing.

When you make purchases through the Services, we may process your payments through a Third-Party application. The Third-Party application may collect certain financial information from you to process a payment on behalf of us, including your name, email address, address and other billing information.

Rights of Access, Rectification, Erasure, and Restriction.

You may inquire as to whether we are processing Personal Data about you, request access to Personal Data, and ask that we correct, amend, restrict access to or delete your Personal Data where it is inaccurate, incomplete or outdated. You may request that we erase your Personal Data in certain circumstances provided by law. You may request that we export your Personal Data to another company, where technically feasible, that we hold in order to provide Services to You. You may send an email to privacy@snapeval.com or use any of the methods set out in this Privacy Policy to request access to, receive, seek rectification, export or request erasure of Personal Data held about You by us. Please include your full name, email address associated with your account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Although we make good faith efforts to provide Individuals with access to their Personal Data, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Data.

Data Retention.

We retain the Personal Data we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and as otherwise required or permitted by law.

Security of Your Information.

We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you from unauthorized access, use, or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

By using the Services providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or sending an e-mail to you. You may have a legal right to receive this notice in writing. If You have reason to believe that Your interaction with us is no longer secure (for example, if You feel that the security of Your account has been compromised), please contact us at privacy@snapeval.com immediately.

Use of Services by Minors.

The Services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Data through the Services.

Jurisdiction and Cross-Border Transfer.

Our services are based in the United States, but may be available to International Users and Data (including Personal Data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer Data to countries outside of Your country of residence, including the United States, which may have data protection rules that are different from those of Your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that Your Data remains protected to the standards described in this privacy policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access Your Personal Data.

International Users.

By using our Services, the Services will transfer data to the United States. By choosing to use our Services or otherwise provide information to us, You agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of New York, United States and the adjudication of any disputes arising in connection with us will be in accordance with the terms of this Privacy Policy.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Data, You consent to any transfer and processing in accordance with this Privacy Policy.

Updates to this Privacy Policy and Notifications.

We may change this Privacy Policy. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services.

We may provide You with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if You are a User, by contacting You through your Snapeval or Spotlight Dashboard, email address and/or the physical address listed in Your account. You agree that electronic disclosures and notices have the same meaning and effect as if we had provided You with hard copy disclosures. Disclosures and notices in relation to this Privacy Policy or Personal Data shall be considered to be received by You within 24 hours of the time they are posted to our website or, in the case of Users, sent to through one of means listed in this paragraph.

Contact Us.

If You have any questions about this Privacy Policy, please contact us at privacy@snapeval.com or at:

Snapeval, LLC
551 Morgan Road
Scottsville, NY 14546
Attention: Legal

Sensitive Information. Because email communications are not always secure, please do not include credit card or other sensitive Data (such as racial or ethnic origin, political opinions, religion, health, or the like) in Your emails to us.

 

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