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Privacy Policy

1. Important Information

1.1. Changes to this Privacy Policy

We may update this Privacy Policy from time to time by posting a new version online. You should check this page occasionally to review any changes. If we make any material changes we will notify you by posting the revised Privacy Policy on our Websites and, if you subscribe to our Subscription Service, providing notice through Notification app in the Atiim portal used to access your Atiim subscription. This helps you to always be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed. Your continued use of the Websites, the Subscription Service, and/or continued provision of Personal Information to us will be subject to the terms of the then-current Privacy Policy.

1.2. Contact Us

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at [email protected] or by mail to Atiim, Inc., 25 First Street, #303, Cambridge, MA 02141 USA, Attn: Privacy.

Our representative in the EU for personal data purposes is Foley Hoag AARPI, you can contact our representative at the following address 153 rue du Faubourg Saint Honoré, 75008 Paris, France.

 

2. Use of Subscription Service by Atiim and Our Customers

2.1. The Subscription Service

We collect the e-mail addresses of those who communicate with us via e-mail, aggregate information on what pages site visitors, consumers and users access or visit, and information volunteered by the consumer (such as survey information and/or site registrations). The information we collect is used to improve the content of our Web pages and the quality of our service, and is not shared with or sold to other organizations for commercial purposes, except to provide products or services you’ve requested, when we have your permission, or under the following circumstances:

It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law.

We transfer information about you if Atiim is acquired by or merged with another company. In this event, Atiim will notify you before information about you is transferred and becomes subject to a different privacy policy.

 

3. Information We Collect

3.1. When You Visit our Websites

You are free to explore the Websites without providing any information about yourself. When you visit the Websites or register for the Subscription Service, we request that you provide Personal Information about yourself.

3.2. Personal Information

You can generally visit our Site without revealing any personal information about yourself. We may, however, collect any information you voluntarily choose to enter or submit to us on our Site when you contact us or register to use the Services or that you provide to us in the course of requesting or receiving support services from us. The types of personal information collected include full name, title, company, employment status, mailing address, email address and telephone number, as well as any additional information you may provide on a form on our Site. The amount and type of personal information that Atiim collects depends on the nature of your interaction with the Site and Services. As a user of our Services, we may have access to any personally identifiable data that you elect to upload to the Services. For example, you may upload details about your team members, such as their name, title, birthday and notes regarding meetings. In addition, we may upload information to the Services, such as photos or job titles, from publicly available profiles on third party sites. Members who sign up for a free trial are not required to enter a credit card.

3.3 How We Use Information

We use your personal information for the following purposes: products and services provision; responding to your requests for information or requests to use our Services; improving our Services; customizing the content you see on the Site; billing; identification and authentication; contact; research; and to send you targeted marketing regarding products and/or services which we believe may be of interest to you. We will not use any of your sensitive personal information for a purpose other than its original purpose for which we collected it or the purpose authorized subsequently by you, unless you have provided opt-in consent.

3.4. Payment Information

We collect and process payment information from you when you subscribe to the Subscription Service, including credit cards numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect Sensitive Information from you.

3.5. We Never Sell Personal Information

We will never sell your Personal Information to any third party.

3.6. Customer Testimonials and Comments

We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.

3.7 Links to Third Party Sites

Our Site may include links to other websites whose privacy practices may differ from those of Atiim. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the Privacy Policy of any website you visit.

3.8 Cookies

A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a web site’s computers and stored on your computer’s hard drive.

Cookies are required to use the Atiim service. You have the ability to accept or decline cookies.  We use cookies to record current session information. You are required to log-in to your Atiim after a certain period of time has elapsed to protect you against others accidentally accessing your account contents.

3.9 How Does Atiim Use Personal Information?

We may use Personal Information:

  • To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our products and services.
  • To send you marketing communications, including via email and SMS in compliance with applicable laws, that we believe may be of interest to you.
  • To send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies.
  • To personalize your experience on the Sites by presenting products and offers tailored to you.
  • To communicate with you and provide you with related customer service.
  • To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these rules carefully.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Sites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our Affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our Affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

3.10 Legal Bases for Processing Your Information

We rely on the following legal grounds to process your personal information:

  • Performance of a contract – We need to collect and use your personal information to perform our agreement with you to deliver the Service as described in this Privacy Policy.
  • Consent – We may use or disclose some of your personal information such as precise location information or collect cookies as described in this Privacy Policy subject to your consent.
  • Legitimate interests – We may use your personal information for our legitimate interests to improve our products and services and the content on our Services. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use technical information as described in this Privacy Policy and use personal information for our marketing purposes.

 

4. Security

Atiim takes steps that are reasonably designed to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, including through secure socket layer, password protection and, for certain transmissions to our Services, encryption. However, due to the open communication nature of the Internet, we cannot guarantee that communications between you and the Site, and the Site and you, will be free from unauthorized access by third parties. Users of the Site do so at their own risk with respect to such communications.

 

5. Geographic Location

5.1 Transfer and Processing of Data

For users within the United States, we process data in data centers located in the United States.  We have adopted reasonable physical, technical, and organizational safeguards against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, access, use, or processing of user data in our possession.  We comply with state and federal laws governing the protection of personal information.

For users within the European Union and Switzerland, we transfer data from the European Union to data centers located in the United States for processing.  Such processing is performed in accordance with Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and free movement of such data, known as the General Data Protection Regulation (“GDPR”).  This includes the imposition of required safeguards with respect to accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of data. Transfers of European Union user data to processors in the United States are made in accordance with the EU-US and Swiss-US Privacy Shield Framework, as explained below.

5.2 Users Located in the European Union and Switzerland

We have undertaken efforts to comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield.  We have undertaken efforts to certify that we adhere to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

If you are a resident of the EU or Switzerland, have the right to:

  • request an accounting of all personal information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).
  • request that we change any personal information that pertains to you.
  • request that we delete any personal information that pertains to you.
  • fully or partially withdraw your consent to the collection, processing, and/or transfer of your personal information.

To request an accounting of your personal information, a change to your personal information, deletion of your personal information, or to withdraw your consent to the collection, processing, and/or transfer of your personal information, contact [email protected] Once we have received notification that you withdraw your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

We commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the EU-US and Swiss-US Privacy Shield Framework.  EU and Swiss residents with Privacy Shield inquiries or complaints should first contact our CTO at [email protected]

We are committed to refer unresolved privacy complaints under the Privacy Shield Framework to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

You also have a right to lodge a complaint with a national Data Protection Authority.  Each European Union member nation has established its own Data Protection Authority; you can find out about the Data Protection Authority in your country here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

 

6. Data Storage

Atiim uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run Atiim. Although Atiim owns the code, databases, and all rights to the Atiim application, you retain all rights to your data.

We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case it is no longer personal information.

It is our policy to retain personal information for 3 months once such personal information is no longer necessary to deliver the Service and to delete such personal information thereafter.  This means that, if you close your account with us, we will delete personal information associated with your account after 3 months. Regarding other types of information we collect as described in this policy (Cookies, Log Files, Geo-Location Information, Device Identifiers), it is our policy to retain such personal information for 3 months and to delete such personal information thereafter.

 

7. Disclosure

Atiim may disclose personally identifiable information under special circumstances, such as in compliance with lawful requests of public authorities, including to meet national security or law enforcement requirements, or when your actions violate the Terms of Service.


Last Updated: May 24, 2018

Comments: Updates to this version of the Privacy Policy reflect changes in data protection law.