With respect to the collection of your information, if you do not want your personal information collected, please do not submit it to us. If you have already submitted information and would like to review, correct or remove it from our records, please contact firstname.lastname@example.org.
1. Types of Information WeSpire Collects and How We Collect it
We collect different personal information from you depending on how you want to engage with WeSpire.
Personal Information Collected on the Site
When you request a demo through the Site, we collect your name, employer information, email address, phone number, and country information so we understand more about you and can communicate with you about the services you have requested. We also collect this information when you request certain downloadable content from the Site so that we can know a little more about who is interested in our content and so we can customize our information to you. But, you can also use certain features of our Site without telling us your name and if you do not tell us who you are, we do not try to find out.
Personal Information Collected on the App
When you sign up to use the App, we will collect your name and email address. In addition, we may have also obtained information about your employment, such as your position and tenure, from the Sponsor who has previously obtained information and appropriate permission and consent from you.
Non-Personally Identifiable Information Collected through our Programs
We also automatically collect non-identifiable data through the Site. For example, we collect certain standard information that your browser sends to every website you visit, such as your IP address, browser type, and language, access times and referring website addresses. We may also use website analytics tools on our site to retrieve information from your browser, including the site you came from, the search engines and keywords you used to find our Site, the pages you view within our Site, the links you click on, and your browser add-ons.
Additionally, we may use technologies, such as cookies and web beacons, to collect information about the pages you view, the links you click and other actions you take on our sites and services. Cookies, web beacons and/or similar technologies were originally designed to help a website distinguish a user’s browser from a previous visitor and thus save and remember any preferences that may have been set while the user was browsing the site or to track the user’s activities.
A cookie is a small text file that is placed on your hard disk by a Web page server. Cookies contain information that can later be read by a Web server in the domain that issued the cookie to you. Cookies cannot be used to retrieve any other data from your hard drive, capture your email address, run programs, or deliver viruses to your computer. A web beacon is a small transparent gif image that is embedded in an HTML page or email used to track when the page or email has been viewed. These assist in delivering cookies on our Site and allow us to count users who have visited those pages. This technology is similar to a cookie in that it tracks your visit and the data can only be read by the server that receives the data. It is different than a cookie in that it is not browser-based, may not function as an identification card, and does not store any data on your computer. You can set your browser to notify you when a cookie is sent or to refuse or delete cookies altogether, but certain features of the Site might not work without certain cookies. You can find out how to do so here: www.aboutcookies.org.
We use Google Analytics as described in “How Google uses data when you use our partners’ sites or apps.” You can prevent your data from being used by Google Analytics on websites by installing the Google Analytics opt-out browser add-on. We also employ IP address masking, a technique used to truncate IP addresses collected by Google Analytics and store them in an abbreviated form to prevent them from being traced back to individual users. Portions of our Site may also use Google Analytics for Display Advertisers including DoubleClick or Dynamic Remarketing which provide interest-based ads based on your visit to this or other websites.
Combining Personal Information with Non- Personally Identifiable Information
If you have actively sent us your name or other personally identifiable information, we may combine such information with tracked information for the purposes set forth below.
2. How We Use Your Information
Information Collected Through our Site
Personal information you provide through our Site is used to provide you with email updates and marketing communications from us about our services, such as newsletters or emails. At a minimum, we will always give you the opportunity to “opt out” of receiving marketing materials you choose to unsubscribe from. Your information may also be used to help us track the way you use our Site and our services. We may also combine the information you provide with information that we collect separately, including information you have provided to other organizations as well as public information. All of this information will help us to better understand your needs and how we can improve our products and services.
If we would like to use your personal information for any purposes other than those described, we will obtain your prior consent.
Information Collected Through our App
Personal information you provide through the App is used for employee engagement research purposes, such as:
- to communicate with you regarding WeSpire’s services and/or your participation in the App;
- for employee engagement research conducted on behalf of the Sponsor;
- to analyze, evaluate and/or improve WeSpire’s App, services and/or engagement research tools; and
- Analyze and measure the success of our App over time
We also may use your information to communicate with you and to provide ongoing service and support. Occasionally we may use your information to contact you to complete surveys that we use for quality assurance purposes. We will not use personal information collected through the App for direct marketing purposes (however, if you have provided your information to WeSpire in other ways, such as through our Site, we may use your information to contact you as set forth above).
3. How we Share and Disclose your Information
We may share your information with people and organizations WeSpire trusts who need your information in order for WeSpire to run its Programs or perform other services related to WeSpire running its business and providing its services.
When you use the App, your name and usage information may be shared with the Sponsor.
In addition, we may send your personal information collected through our Programs to other companies or people under any of the following circumstances:
- When we have your consent to share the information (if required under local law);
- In connection with the sale, merger, divestiture, reorganization or any other corporate transaction involving WeSpire;
- To third party service providers who help us with our business operations or other aspects of our business; and
- For data and customer relations management, passing your data to our contracted service providers.
We only share personal information with other trusted third-party businesses or persons for the purpose of performing services on our behalf. We require that these parties only process the personal information for limited and specified purposes consistent with this Policy.
We reserve our right to disclose your personal information if we have a good faith belief in our sole discretion that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Legal Notice and terms of Program participation, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of WeSpire, its users or the public as required or permitted by law. You cannot opt out of disclosure of your personal information if required by lawful order. We do not share the information you provide with third parties for their direct marketing purposes.
If we would like to share your personal information for any purposes other than those described, we will obtain your prior consent.
Please remember that any content you choose to post in our Programs may be accessible to other users of WeSpire.
4. About Children
Our Programs are not intended for children under the age of 16. We do not knowingly collect personally identifiable information through our Programs from visitors in this age group. If we learn that we have collected personal information about a child under 16, we will delete that information as quickly as possible. If you believe we may have collected information about a child under 16, please contact us at email@example.com.
5. How Long We Keep Your Personal Information
We typically only retain your information for as long as necessary to realize our legitimate business purposes and to comply with the law.
6. How We Keep Your Information Safe
WeSpire safeguards the personal information you send us and takes reasonable physical, technical, and organizational measures to prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to your personal information. We use industry-standard efforts to safeguard the confidentiality of personally identifiable information, including encryption, firewalls and SSL (Secure Sockets Layer). While we strive to protect your personal information, we need your co-operation to ensure the security of the information you transmit to us. We urge you to take every precaution to protect your personal information while using the Internet. Change your passwords often, and use a passphrase instead of password with at least 8 characters in combination of letters and numbers. Make sure you use a secure internet browser, follow the vendor suggestion and apply updates when required.
7. Access and Correction Your Profile and Preferences
Please keep your personal information, accurate, current, and complete by routinely updating your user profile. You have the right to access your personal information and correct, amend or delete this data if it is inaccurate or if it is not otherwise required to be retained by law or for legitimate business purposes.
If you have created a profile through the App you may logon and review your personal iinformation on your Account information page and make changes from there. If there is something you wish to change but cannot from your Account page, then contact us and we will help.
Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information, please contact us at firstname.lastname@example.org.
You may modify your communication preferences and/or opt-out from specific communications from our Programs at any time. Please specify and adjust your preferences by clicking the unsubscribe link of any email you receive or by contacting us at email@example.com.
8. Visiting our Site from Outside the United States
9. Visiting our Site from the European Economic Area (EEA) and Switzerland
The Legal Basis for Using European Personal Information
When we collect information about you through our Site, the legal basis on which we process your personal information is our legitimate interests, namely, to provide you with the WeSpire communications and other information marketing our Programs. If we have received your personal information in some other way and wish to provide you with the WeSpire communications and other information marketing our Programs, we will do so only on the basis of your consent.
Storage and Processing of Personal Information Outside the EEA and Switzerland
If you are located in the EEA or Switzerland, please note that as part of our service, we may transfer your personal information to other regions, including to the United States.
To learn more about the Privacy Shield program and to view our certification, please visit: www.privacyshield.gov
Rights and Choices for EEA Residents
In addition, if you are a resident of the EEA, you have the right to:
- Find out if we use your personal information, to access your personal information, and receive copies of your personal information.
- Withdraw your consent to the processing of your personal information at any time without penalty.
- Access your personal information and have it corrected or amended if it is inaccurate or incomplete.
- Obtain a transferable copy of some of your personal information which can be transferred to another provider when the personal information was processed based on your consent.
- If you believe your personal information is inaccurate, unlawful, no longer necessary for our business purposes, or if you object to our processing of your personal information, you also have the right to instruct us to restrict the processing of your data pending our investigation and/or verification of your claim.
- Request your personal information be deleted or restricted under certain circumstances. For example, if WeSpire is using your personal information on the basis of your consent and has no other legal basis to use such, you may request your personal information be deleted when you withdraw your consent.
If you wish to exercise any of these rights, or raise a complaint on how we have handled your personal information, please contact us at the details below.
If you are not satisfied with our response, or believe we are processing your personal information in violation of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data Protection Authority) in your EEA country. For our operations within the EEA, our Lead Supervisory Authority is the UK Information Commissioner’s Office (www.ico.org.uk)
Sharing European and Swiss Personal Information
WeSpire complies with European and Swiss privacy principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
We only share European and Swiss personal information with other trusted third-party businesses or persons who have agreed to
- only process the personal information for limited and specified purposes consistent with your consent;
- provide the same level of protection for personal information as is required by European privacy principles; and
- notify WeSpire and cease processing personal information (or take other reasonable and appropriate remedial steps) if the company determines that it cannot meet its obligation to provide the same level of protection for personal information as is required by European and Swiss privacy principles.
WeSpire has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. WeSpire conducts an annual self-assessment of its Personal Information practices to verify that the attestations and assertions WeSpire makes about its Privacy Shield privacy practices are true and that WeSpire’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.
You may file a complaint concerning WeSpire’s processing of your Personal Information. WeSpire will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. You may contact WeSpire as specified below about complaints regarding WeSpire’s personal information practices.
In compliance with the Privacy Shield Principles, WeSpire commits to resolve complaints about our collection or use of your Personal Information. EU and Swiss individuals with inquiries or complaints regarding our Private Shield policy should first contact WeSpire at firstname.lastname@example.org.
WeSpire has further committed to refer unresolved Privacy Shield complaints to JAMs, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact of visit JAMs complaint handling page https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMs are provided at no cost to you.
WeSpire is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) to ensure compliance with the EU-US and Swiss-US Privacy Shield principles outlined in this policy.
If your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
10. Use of the WeSpire App
If you choose to use the App, you will need to provide your login and password to access and complete mobile activities. Multimedia will only be collected from your device if you affirmatively select it for submission through the App (i.e. you chose an image or video to submit for an activity). Any information and content collected through the App will be used consistent with this Policy.
11. Third Party Sites
14. Contacting Us
180 Lincoln St.
Boston, MA 02111
Updated: July 19, 2018