OPENPRISE INC. PRIVACY AND COOKIE POLICY
Effective August 10, 2020

Introduction

This privacy and cookie policy (“Policy”) describes how Openprise, Inc. (“Company,” “we,” and “our”) collects, uses and shares personal data when using this website www.openprisetech.com (the “Site”) and/or the www.openprisecloud.com applications(s), (the “Applications”), together (the “Services”). Please read the following information carefully to understand our views and practices regarding your personal data and how we will treat it.

Privacy Shield Certification

Openprise, Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  Openprise has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles and is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In the context of an onward transfer, Openprise has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Openprise shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Openprise commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Openprise at:

privacy@openprisetech.com

Openprise has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.

You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances.  For further information, please see the Privacy Shield website.

Particularly Important Information

Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is Openprise, Inc. of 1900 S. Norfolk Street, Suite 210, San Mateo, California 94403, USA. Our data protection officer is Reynauld Ong.

Must Read Sections: We draw your attention in particular to the sections entitled “International Data Transfer” and “Your Rights.”

Changes to this Policy: We will post any modifications or changes to the Policy on our site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email and post a notice on our site prior to such changes(s) taking effect.

Openprise adheres to the Privacy Shield Principles.

1. Purposes of Processing

What is personal data?

We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the [UK Data Protection Act 1998/the European Data Protection Directive 95/46/EC/General Data Protection Regulation 2018] and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.

Why do we need your personal data?

We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Services. If you created a profile/registered with us, you will have been asked to tick to agree to provide this information in order to access our services, purchase our products, view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Services.

2. Collecting Your Personal Data

We collect information about you in the following ways:

Information You Give Us. This includes:

• the personal data you provide when you register to use our Services, including your‎ name, postal address, email address, telephone number, username, password and demographic information (such as your title);
• the personal data that may be contained in any video, comment or other submission you upload or post to the Services;
• the personal data you provide in connection with our rewards program or other promotions we run on the Services;
• the personal data you provide when you report a problem with our Services or when we provide you with customer support;
• the personal data you provide when you make a purchase thorough our Services; and
• the personal data you provide when you correspond with us by phone, email or otherwise.

Information from Social Networking Sites. Our Services include(s) interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Services, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

Information We Get from Others. We may also get information about you from other sources, for example, if you have agreed to share information with one of our partners that distributes our content, we may add this to information we get from our Services. This may include but not limited to the personal data you provide when you register with our partners, such as your‎ name, postal address, email address, telephone number, username, password and demographic information (such as your title).

Google User Profile. For customers who explicitly connects Openprise to Google Drive and/or Google APIs including but not limited to Google Places, Google Search, and Google Translate, Openprise utilizes OAuth to access and collect your Google user profile. Openprise will store your Google OAuth access token and Google user email, but customers can explicitly remove the stored OAuth access token and Google user email from Openprise through the user interface. The OAuth access token and Google user email will be stored in Openprise for the sole purpose of:

• Connecting to your Google Drive to access CSV and Google Sheet files containing the data you wish to import into Openprise.
• Connecting to your Google APIs to consume the services.

Openprise may NOT use such personally identifiable information from Google for the purpose of selling or sending any such customer information to our partners, customers, or any third-party.

Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Services. For example, when visiting our Services, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Services. We collect this information about you using cookies. Please refer to the sections on cookies, Flash Technology and Pixel Tags below.

Automated Decision Making and Profiling. We may use automated decision making and/or profiling in regard to your personal data for some services and products, for example evaluate your propensity and readiness to purchase our Services based on demographic data and activity history. You can request a manual review of the accuracy of an automated decision that you are unhappy with or limit or object to such automated decision making and/or profiling by contacting us at privacy@openprisetech.com.

3. Cookies

What are cookies?

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Services.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Services; and (2) third party cookies, which are served by service providers on our Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies we use

Our Services use the following types of cookies for the purposes set out below:

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.

4. Pixel Tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on [our Site/Application(s)/Services] to track the actions of users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of our Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.

5. Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

6. Using Your Personal Data

We may use your personal data as follows:

• to operate, maintain, and improve our Services, products, and services;
• to manage your account, including to communicate with you regarding your account, if you have an account on our Services;
• to operate and administer our rewards program and other promotions you participate in on our Services;
• to respond to your comments and questions and to provide customer service;
• to send information including technical notices, updates, security alerts, and support and administrative messages;
• with your consent, to send you marketing e-mails about educational content, upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
• to link or combine user information with other personal data;
• as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
• as described in the “Sharing of your Personal Data” section below.

7. Sharing Your Personal Data

We may share your personal data as follows:

• Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
• Our Third-Party Service Providers. We may share your personal data with our third-party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
• Affiliates. We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.
• Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
• Other Disclosures. e may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

8. Anonymous Data

When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.

We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies.  We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you.  We use this anonymous data to analyses usage patterns in order to make improvements to our Services.

9. Third Party Sites

Our Services may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.

10. User Generated Content

You may share personal data with us when you submit user generated content to our Services, including via our rewards program, forums, message boards, blogs, and Open Data Catalog on our Services. Please note that any information you post or disclose on our Services will become public information, and will be available to other users of our Services and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on our Services. Such personal data and other information will not be private or confidential once it is published on our Services.

If you provide feedback to us, we may use and disclose such feedback on our Services, provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your first and last name along with your feedback on our Services. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.

11. International Data Transfer

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

12. Security

We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 19 below.

13. Retention

We will only retain your personal data as long reasonably required for you to use our Services and/or to provide you with the Services unless a longer retention period is required or permitted by law (for example for regulatory purposes).

14. Our Policy on Children

Our Services are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in Section 19 below. We will delete such information from our files as soon as reasonably practicable.

15. Sensitive Personal Data

Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

If you send or disclose any sensitive personal data to us when you submit user generated content to our Services, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our Services.

16. Your Rights

• Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the Services may be ineffective upon opt-out.
• Access. You may access the information we hold about you at any time via your profile/account or by contacting us directly.
• Amend. You can also contact us to update or correct any inaccuracies in your personal data.
• Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
• Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us using the details in Section 19 below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. 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. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

17. Complaints

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: privacy@openprisetech.com. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.

18. Contact Information

We welcome your comments or questions about this Policy. You may contact us in writing at privacy@openprisetech.com or 303 Twin Dolphin Drive, Suite 600, Redwood City, California 94065, USA.

19. Employee Personal Data

Openprise, Inc. commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to human resources data transferred from the EU in the context of the employment relationship. Please contact us to be directed to the relevant DPA contacts.