Ecobot Privacy Policy

Effective Date: January 13, 2019

This is the Privacy Policy for Ecobot, Inc. ("Ecobot") and its affiliates. It covers our handling of two categories of information:

  1. Personal data we handle for our customers and users ("Service Data") - We collect this data through our environmental consulting productivity management and collaboration platform (including through user accounts on Ecobotapp.com and our apps) and through related support and professional services. We refer to all of these offerings as the "Services." Under applicable law, Ecobot is considered a "processor" of this data, and the user (or, for organizations with access to the admin console, the customer) is a "controller" of the data.
  2. Personal data we handle for our own business ("Business Data") - This includes certain data collected on our websites, such as newsletter signup forms, as well as data collected through other marketing-related efforts. Under applicable law, Ecobot is a "controller" of this data.

This Privacy Policy has details specific to Service Data, details specific to Business Data, and information relevant to our handling of both kinds of data. This Privacy Policy does not apply to the collection of the information by third-party websites or applications, including applications for Ecobot jobs. We encourage you to review the privacy policies of third-party websites and applications with which you interact.

1. Privacy Practices Specific to Service Data

a. Types of Service Data

We receive information from or on behalf of our customers and their users. Because of the nature of our Services, this Service Data may contain any type of personal data but almost always is professional contact information. Our platform also uses cookies and other automated data collection tools described in Section 3 to collect Service Data. We use Service Data as described below.

b. Uses of Service Data

Subject to our contractual obligations, and depending on the particular Ecobot Services, we use the information described above as follows:

c. Disclosures of Service Data

Subject to our contractual obligations, and depending on the particular Ecobot Services, we share the information described above as follows:

For those purposes, we may share Service Data with our affiliates and other entities that help us with any of the above.

2. Privacy Practices Specific to Business Data

a. Types of Business Data

Business Data consists of contact details, professional details (e.g., title and name of company), information about an individual's interactions with Ecobot or our partners, and payment information that we collect for our own business activities, as opposed to data that we collect on behalf of a particular customer.

We obtain Business Data directly from the relevant individuals, and also from third-party sources, such as their employers, marketing or lead generation companies and other third-party data aggregators, and social networking platforms (e.g., LinkedIn).

Our platform also uses cookies and other automated data collection tools described in Section 3. We use the Business Data collected through such technology as described below.

b. Uses of Business Data

Ecobot uses and discloses Business Data as follows:

c. Disclosures of Business Data

Subject to our contractual obligations, we share the information described above as follows:

For those purposes, we may share Business Data with our affiliates and other entities that help us with any of the above.

d. Legal Basis for Processing Business Data

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds for processing Business Data are as follows:

(We process Service Data pursuant to our contracts with our customers and applicable law.)

3. Additional Information About Our Privacy Practices (applicable to both Service Data and Business Data)

a. Security and Data Retention

To provide security for Service Data, we maintain physical, organizational and technical safeguards, which are subject to periodic changes. We use different safeguards to help secure Business Data.

If you use third-party software integrated into our service (for example, Google Drive, Box, Dropbox or other integrations), your information will be handled by such third party subject to their own privacy and security policies or procedures, which we do not control.

We will hold your information for as long as necessary to fulfill the purposes set forth in this Privacy Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.

b. Personal Data Rights and Choices (including Direct Marketing Opt-Out)

All users can review and update certain user information by logging in to the relevant portions of the Ecobot platform. You can unsubscribe from marketing emails by clicking the "unsubscribe" link they contain. Users can deactivate their accounts by contacting us at privacy@ecobotapp.com, subject to any contractual provisions between Ecobot and the customer responsible for the account. Controls related to cookies and other automated data collection are described in the section below.

Residents of the European Economic Area, Canada, Australia and many other jurisdictions have certain legal rights (including, in certain cases, under the EU-U.S. and EU-Swiss Privacy Shield Frameworks after our Privacy Shield certification takes effect) to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. In limited cases, they have the right to receive information we hold about them in portable form and to have it transmitted to a third party. They also have rights to object to our handling of their personal data, to restrict its processing, and to withdraw any consent they have provided.

For example, individuals have a right to opt out of our processing of Business Data for direct marketing purposes.

To exercise those rights, they may contact us as described at the end of this Privacy Policy. Where we process personal data on behalf of our customer, we may refer the request to the relevant customer and cooperate with their handling of the request, subject to any special contractual arrangement with that customer. For individual user accounts not associated with a customer account, Ecobot will handle the request directly.

Many of the rights described above are subject to significant limitations and exceptions under the Privacy Shield Frameworks and applicable law. For example, objections to the processing of personal data, and withdrawals of consent, typically will not have retroactive effect. Individuals also have a right to lodge a complaint with the relevant supervisory authority, but we encourage individuals to contact us first, and we will do our best to resolve any concern.

c. Cookies and Automated Data Collection

In our websites, apps and emails, we and third parties may collect certain information by automated means such as cookies, Web beacons, JavaScript and mobile device functionality. This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as the Apple IDFA or Android Advertising ID), geolocation, other device information, Internet connection information, as well as details about individuals' interactions with our apps, websites and emails (for example, the URL of the third-party website from which you came, the pages on our website that you visit, and the links you click on in our websites).

We and third parties may use automated means to read or write information on users' devices, such as in various types of cookies and other browser-based or plugin-based local storage (such as HTML5 storage).

Cookies and local storage are files that contain data, such as unique identifiers, that we or a third party may transfer to or read from a user's device for the purposes described in this Privacy Policy, such as recognizing the device, service provision, record-keeping, analytics and marketing, depending on the context of collection.

You may be able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being sent. Some browsers offer similar settings for HTML5 local storage. However, if you block or otherwise reject our cookies, local storage, JavaScript or other technologies, certain websites (including our own websites) may not function properly.

These technologies help us (a) keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you; (b) remember your settings on the pages you visit, so that we can display your preferred content the next time you visit; (c) display personalize content; (d) perform analytics, and measure traffic and usage trends, and better understand the demographics of our users; (e) diagnose and fix technology problems; and (f) otherwise plan for and enhance our business.

Also, in some cases, we facilitate the collection of information by advertising services administered by third parties. The ad services may track users' online activities over time by collecting information through automated means such as cookies, and they may use this information to show users ads that are tailored to their individual interests or characteristics and/or based on prior visits to certain sites or apps, or other information we or they know, infer or have collected from the users. For example, we and these providers may use different types of cookies, other automated technology, and data (a) to recognize users and their devices; (b) to inform, optimize, and serve ads; and (c) to report on our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services (including how they are related to visits to specific sites or apps).

To learn more about interest-based advertising generally, including how to opt out from the targeting of interest-based ads by some of our current ad service partners, visit aboutads.info/choices or youronlinechoices.eu from each of your browsers and devices.

You can opt out of Google Analytics and customize the Google Display Network ads by visiting the Google Ads Settings page. Google also allows you to install a Google Analytics Opt-out Browser Add-on for your browser.

If you replace, change or upgrade your browser, or delete your cookies, you may need to use these opt-out tools again. We do not respond to browser-based do-not-track signals.

Please visit your mobile device manufacturer's website (or the website for its operating system) for instructions on any additional privacy controls in your mobile operating system, such as privacy settings for device identifiers and geolocation.

d. International Data Transfers

We are based in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as the country in which you are located. Ecobot complies with legal requirements for cross-border data protection, including through the use of European Commission-approved Standard Contractual Clauses and contract language required by the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks ("Privacy Shield"), which is described below.

As a business subject to the investigatory and enforcement authority of the United States Federal Trade Commission, Ecobot has certified that its U.S. operations adhere to the Privacy Shield with respect to the personal data that Ecobot receives in reliance on the Privacy Shield. Our Privacy Shield certification has been submitted, and it will be available at https://www.privacyshield.gov/list when it takes effect. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov.

When Ecobot receives personal data under the Privacy Shield and then transfers it to a third-party service provider acting as an agent on Ecobot's behalf, Ecobot may have certain responsibility under the Privacy Shield if both (a) the agent processes the information in a manner inconsistent with the Privacy Shield and (b) Ecobot is responsible for the event giving rise to the damage.

Covered European residents should direct any questions, concerns or complaints regarding Ecobot's compliance with the Privacy Shield to Ecobot as described at the bottom of this Privacy Policy. Ecobot will attempt to answer your questions and satisfy your concerns in a timely and complete manner as soon as possible. If, after discussing the matter with Ecobot, your issue or complaint is not resolved, Ecobot has agreed to participate in the Privacy Shield independent dispute resolution mechanisms listed below, free of charge to you. PLEASE CONTACT Ecobot FIRST.

Ecobot has committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism. Please visit JAMS for more information.

If your complaint still is not resolved through these channels, under limited circumstances, an additional binding arbitration option may be available before a Privacy Shield panel, as described at https://www.privacyshield.gov.

Please note that Ecobot's customers may transfer personal data to Ecobot on the basis of other legal mechanisms approved by the European Commission and other relevant authorities for cross-border data transfers, such as Standard Contractual Clauses. To exercise any legal right to see copies of the data transfer mechanism documents that Ecobot uses to transfer data to third parties, please contact us. Our product allows our customers and users to make international data transfers to third parties, for which they are solely responsible.

e. Notification of Changes

Ecobot may change this Privacy Policy to reflect changes in the law, our data handling practices or the features of our business. The updated Privacy Policy will be posted on https://www.ecobotapp.com/privacy.

f. Contact Information

If you have questions regarding our practices or this Privacy Policy, or to send us requests or complaints relating to personal data, please contact us at privacy@ecobotapp.com or as follows:

UNITED STATES

Ecobot, Inc. 1 Haywood Street, Suite 401, Asheville NC 28801. Telephone: +1 (828) 423-0808.