Adopted January 22, 2016.
FADEL collects certain personal information you provide when interacting with our Platform. If you decide to create an account, participate in a survey, contest or sweepstakes, subscribe to one of our Platforms, interact with one of our Portals or Partner Marketplace, contact us, request a demo, download a whitepaper, or otherwise interact with our Platform or other users on our Platform, any personally identifiable you provide in conjunction with that communication may be collected (for example, your first and last name, email address, associated company information, telephone number, contact preferences, and usage preferences). In some circumstances, you may be asked to provide and we may then collect information about the company you are affiliated with, including without limitation the company’s description, logo, product description, contact information for sales, support, and additional product details.
When you create an account, your account profile page will be created in part based upon the information you provide at that time or at a later time. Such information may include but is not limited to your name, title, company name, telephone number, email address, account user name and password, and complete mailing address.
When you visit or interact with the Platform, FADEL automatically receives certain information from or about your computer, mobile phone or other electronic device used to access the Platform via standard communications protocols (including information like your network routing information, operating system, browser type, Internet Protocol (“IP”) address, time and date). We may use your IP address to gather broad demographics information so that we can analyze trends and better administer the Platform. And when you create an account, we log the IP address from which the account was created.
Often in conjunction with cookies, we may employ web beacons or pixels (electronic files or little blocks of code on a webpage) in order to tabulate Site and Application visits and track activity over time, or aggregate other related information. This information may be associated with your IP address or unique browser identifier.
FADEL may use third party service providers to track and analyze statistical information such as usage and volume from users to the Site and Application (as well as across other websites). Information aggregated may include content you view, the date and time you view this content, and the web site that referred you to the Platform, and may be associated with your unique browser, device identifier, or IP address.
A profile page may be created for you based on the information you provide (or, in some instances, which is provided on your behalf by someone else in your organization).
Respond to or take other action regarding your queries, support requests, or further communicate with you regarding our Platforms, promotional events, sweepstakes or contests, or regarding your account. (If you contact us, we may collect and retain any information associated with that message.)
Improve the quality of our Platform and user experience (including the use of information obtained from third parties, cookies and other technologies).
Perform internal operations (for example, troubleshooting, data analysis, testing, research and service improvements).
Create and deliver personalized content by aggregating personal information with non-personal information.
You may have the opportunity to receive special offers or information from third parties, or request additional information from one of our affiliates or partners. By this request, you’re granting FADEL permission to transfer your personal information for the purpose of fulfilling your request.
FADEL may also disclose anonymous, aggregated data statistics to current and prospective partners and affiliates, service providers or other third parties. This type of data does not personally identify an individual, and cannot be linked to a specific user. It can, however, provide valuable insight into general Site and Application usage and trends among various groups.
We sometimes receive aggregated data from our affiliates, advertising partners and other third parties that assists us (or them) in understanding user activity and making improvements to our Platform. FADEL may match third party data with information about our Platform users and visitors.
In limited circumstances, we may use, preserve or disclose your personal information if we have a good faith belief that it is reasonably necessary to prevent, identify, or respond to fraudulent or illegal activity, or to protect us, you or others from harm. If we have a good faith belief that it is required by law, FADEL may preserve or share personal information in response to a legal request (such as a court order, subpoena or search warrant). We may also use it to identify or address a potential violation of our Terms of Service, or for administrative or other purposes that we deem necessary to maintain or improve our Platform.
Upon a merger, acquisition, reorganization, transfer or sale of some or all of our assets or other similar transaction or event, personal information may be transferred together with the business.
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal basis for doing so under applicable EU laws. The legal basis depends on the Platform you use and how you use them. This means we collect and use your information only where:
· We need it to provide you the Platform, including to operate the Platform, provide customer support and personalized features and to protect the safety and security of the Platform;
· It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Platform and to protect our legal rights and interests;
· You give us consent to do so for a specific purpose; or
· We need to process your data to comply with a legal or contractual obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Platform.
FADEL will employ reasonable measures to safeguard your personal information when you interact with our Platform (including the use of secure servers, secured socket layer (SSL) technology, and maintenance of your personal information in databases hosted in the US) in order to help prevent unauthorized access, disclosure or use of this information. However, no online transmission can be guaranteed to be 100% secure. You are responsible for taking reasonable steps to safeguard the security of your account and password; be sure to sign off from your account if using a shared computer, use a secure web browser, and change your password often. If you have any questions about security on our Platform, please contact your Account Manager.
In most instances, only users with administrative access can update personal information or user information for an account. If you want to modify how FADEL communicates with you or delete your user account, you can you accomplish this by logging in to your account.
Our email correspondence with you will include instructions on how to opt out of future promotional emails. Please note that we may still send you non-promotional emails – for example, in order to make disclosures mandated by legal requirements.
If permitted by your browser, you can also change your browser preferences to reject or notify you about cookies, or delete them after leaving the Site.
Please contact Support if you are a customer and have questions or need assistance about managing your personal information.
We offer publicly accessible blogs, forums, issue trackers, and wikis like Rights Cloud™ Community. You should be aware that any information you provide on these websites - including profile information associated with the account you use to post the information - may be read, collected, and used by any member of the public who accesses these websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these Platforms. To request removal of your information from publicly accessible websites operated by us, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
We use data hosting service providers in the United States and the European Union to host the information we collect, and we use technical measures to secure your data.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
How long we keep information we collect about you depends on the type of information, as described elsewhere in this document. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Platform. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Platform. Where we retain information for Platform improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Platform, not to specifically analyze personal characteristics about you.
If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Platform. For example, we continue to display messages you sent to the users that received them and continue to display content you provided.
If the Platforms are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account.
If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Platform, such as when you last opened an email from us or ceased using your FADEL account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
The Services are not intended for use by anyone under the age of 18. Those under 18 years of age may not create an FADEL account, and we do not knowingly collect information from visitors under the age of 18. Because the safety of children is as important to you as it is to us, please contact us at 646-736-6083 if you are aware of any use by someone under the age of 18 (or any use that otherwise violates the Children’s Online Privacy Protection Act of 1998).
Under California Civil Code Section 1798.83 (also known as S.B. 27, or the “Shine the Light” law), residents of California may (subject to the provisions of the law) request certain details regarding what personal information (if any) is shared with third parties for the purposes of the third parties’ direct marketing purposes. If you want to make a request or have questions regarding your rights under California law, you can write us at FADEL, Attn: Compliance Officer, 22 Elm Place, Floor 4, Rye, New York 10580. If FADEL is not exempt from S.B. 27 and your request complies with the law’s requirements, we will provide you with a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, together with the third parties’ names and addresses.
FADEL is a registered trademark of Fadel Partners, Inc.
Rights Cloud is a trademark of Fadel Partners, Inc.
IPM Suite is a trademark of Fadel Partners, Inc.
Licensing Cloud is a trademark of Fadel Partners, Inc.
ARC is a trademark of Fadel Partners, Inc.
Last updated: November 27, 2018