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Privacy Policy

Effective May 2017

This privacy statement describes how we collect and use the personal information you provide on the Site. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. Submittable Holdings Inc. (“we” or “us”) complies with the EU-US Privacy Shield Agreement.

Submittable Holdings Inc. complies with the EU-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 to the United States. Submittable Holdings Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. 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/.

Collection of Personal Information

We collect the following types of personal information from you:

  • Contact Information such as first and last name, email address, mailing address, and phone number

  • Billing Information such as credit card number, security code, expiration date, and billing address

  • Unique Identifiers such as a user name and password chosen by you, account number, Facebook UID, and other identifiers assigned to you by us or a third-party you have authorized by establishing an account or other relationship

  • Preferences Information such as action history, marketing preferences, information desired or rejected, and other selections made by you

We may also collect the following information from you:

  • Demographic information such as age, education, gender, interests, and zip code.

  • Location information such as GPS locations, IP address, street address, city, state, phone number

Use of Personal Information

We use the information collected from you to:

  • Communicate with you

  • Collect fees for services and products approved for purchase by you

  • Authenticate your access to our site and your information stored by us

  • Provide services and improve those services

As is true of most Web sites, we automatically gather information about your computer such as your IP address, browser type, referring/exit pages, and operating system. We use this information to:

  • Fulfill your account / order

  • Send you an order confirmation

  • Assess the needs of your business to determine suitable products

  • Send you requested product or service information

  • Send product updates or warranty information

  • Respond to customer service requests

  • Administer your account

  • Send you a newsletter

  • Send you marketing communications

  • Respond to your questions and concerns

  • Improve our Website and marketing efforts

  • Conduct research and analysis

  • Display content based upon your interests and location

  • Facilitate your transactions with other users

Limitations on Use: Choice/Opt-In

Your data will never be used for a purpose that is incompatible with the original purpose for which it was collected UNLESS you specifically Opt-In to such use through a clear and distinctive affirmation process fully explained to you by us through an electronic process (i.e. dialog box, prompt, or the like).

Limitations on Use: Choice/Opt-Out

Your data may be used for a new purpose different from, but related to, the original purpose (i.e. materially different). Such use will only occur if you do not object. We will always notify you of such use and provide an Opt-Out option for such use.

Limitations on Use: Information Sharing

We will share your personal information if the new purpose is different from the original purpose but would not be considered materially different. Within such use, we may use and disclose your Personal Information as follows:

  • To promote use of our Services. For example, if you leave your Personal Information when you visit our Website and don’t sign up for any of the Services, we may send you an email asking if you want to sign up. And if you use any of our Services and we think you might benefit from using another Service, we may send you an email about it. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send.

  • To send you informational and promotional content that you may choose (or ‘opt in’) to receive. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.

  • To bill and collect money owed to us. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see Section 12 below.

  • To send you System Alert Messages. For example, we may let you know about temporary or permanent changes to our Services, like planned outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy.

  • To communicate with you about your account and provide customer support.

  • To enforce compliance with our Terms of Use and applicable law. This may include developing tools and algorithms that help us prevent violations.

  • To protect the rights and safety of our Members and third parties, as well as our own.

  • To meet legal requirements such as complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.

  • To provide information to representatives and advisors, such as attorneys and accountants, to help us comply with legal, accounting, or security requirements.

  • To prosecute and defend a court, arbitration, or similar legal proceeding.

  • To provide, support, and improve the Services we offer. This includes aggregating information from your use of the Services and sharing such Aggregated Information with third parties.

  • To provide suggestions to you. This includes adding features that compare Members’ email campaigns, or using data to suggest other publishers your Subscribers may be interested in.

  • To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We’ll notify you of the change either by sending you an email or posting a notice on our Website.

Cookies and Other Tracking Technologies

We may use cookies, for example, to keep track of your preferences and profile information. Cookies are also used to collect general usage and volume statistical information that does not include personal information.

We use another company to place cookies on your computer to collect non-personally identifiable information to compile aggregated statistics for us about visitors to our site.

Web Beacons

Our Web pages contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.

Our Web pages may also contain electronic images known as Web beacons (sometimes called single-pixel gifs) that are set by our third party partners. Web beacons are used along with cookies enabling our partners to compile aggregated statistics to analyze how our site is used.

We use a third party to gather information about how you and others use our Web site. For example, we will know how many users access a specific page and which links they clicked on. We use this information in the aggregate ONLY to understand and optimize how our site is used.

Links to Other Web Sites

Our Site includes links to other Web sites whose privacy practices may differ from ours. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.

Security

The security of your personal information is important to us. When you enter sensitive information (such as credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

If you have any questions about security on our Web site, you can contact us by writing or email us at the address below.

Correcting and Updating Your Personal Information

To review and update your personal information to ensure it is accurate, contact us by writing or email us at the address below.

Notification of Privacy Statement Changes

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we may notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site or your Account prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Right to Access Your Personal Information

You may at any time, and for any reason, request access to your personal information by contacting us at the address below. We will provide such access within a reasonable time using methods we choose to insure your access does not compromise other’s data or our ability to conduct business efficiently.

Right to Control Your Personal Information

You may at any time control access to and use of your personal information by contacting us at the address below. Such control will include the ability to Opt-Out of any use of your personal information and to prevent disclosure to any third-party except as required by law or the order of a court of proper jurisdiction.

Right to File a Complaint as to Your Personal Information

You have the right to contact us with a complaint about the use of your information at the address below with the subject line “ATTENTION PRIVACY SHIELD COMPLAINT OFFICER” and all such complaints shall be handled within 45 days. In the event the issue cannot be resolved, alternative dispute resolution in the state of MONTANA will be used to resolve the issue.

Submittable Holdings Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and/or the Department of Transportation. Under certain conditions, it is possible for you to invoke binding arbitration. You should understand that Submittable Holdings Inc. may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or as required by of a court of proper jurisdiction. Submittable’s liability in cases of onward transfers to third parties is limited to actual damages sustained by you.

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

Submittable Holdings, Inc.
111 N. Higgins Ave, 3rd Floor
Missoula, Montana, United States 59802
Email: info@submittable.com

Complaints will be received by the PRIVACY SHIELD COMPLAINT OFFICER who will:

  • Acknowledge the complaint through communication with the complainant.

  • Open an active complaint file (hard copy or electronic).

  • Investigate the complaint by communicating with the complainant and Submittable Holdings Inc. staff.

  • Identify a resolution plan and share the resolution plan with the complainant.

  • Monitor execution of the resolution plan to completion.

  • Inform the complainant of completion of the plan.

  • If acceptable to the complainant, close the complaint file, otherwise revise and re-implement the resolution plan or enter mediation.

Submittable Holdings, Inc. has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association (AAA), an alternative dispute resolution association with an existing relationship with the Privacy Shield Program. 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 Dr. Joel Henry, Esq., at jhenry@wordenthane.com.

AAA’s Privacy Shield page can be found here: http://go.adr.org/privacyshield.html.

Contact Information

You can contact us about these terms of use and privacy policy, or with inquiries and complaints, by writing or emailing us at:

Submittable Holdings, Inc.
111 N. Higgins Ave, 3rd Floor
Missoula, Montana, United States 59802
Email: info@submittable.com

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