EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Arxan Technologies, Inc. and its subsidiary (Apperian Inc.) participate in and have certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov]
Arxan is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Arxan complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Arxan is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Arxan Technologies, Inc.
650 California Street Suite 2750 San Francisco, CA 94108
As to Apperian EASE Services, “visitor” has a special meaning. It means both (a) those who register as EASE administrators for their companies or who are otherwise designated by their companies as their EASE administrators and (b) those who register as EASE end users. In this policy, an individual of type (a) is referred to as an “EASE Administrator” and an individual of type (b) is referred to as an “EASE End User”.
- WHAT DO WE COLLECT AND WHERE?
For example, the information we collect may include your personal information, such as your name, email address, organization name, title, contact information, IP addresses, device identifiers, product and service selections and orders or other things that identify you individually.
You may visit our Websites in any of the following ways:
By using your browser to navigate to our Websites including (but not limited to) www.arxan.com, https://developer.arxan.com/login, www.apperian.com , https://ease.apperian.com , https://ease.apperian.eu
By viewing an advertisement displayed on a third party website that is served content by our web server;
By viewing an email that is served content by our or a third party web server.
Non-Personal and Aggregated Information Collected Automatically
When you visit our websites, we log general data, such as your domain name, the name of the Web page from which you entered our websites, which pages you visit on our websites, and how much time you spend on each page. We use this information to monitor use of and improve our websites as well as for internal analysis.
We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
Links to non-Arxan Websites
Personal information received from the EU and Switzerland
When Arxan is a data controller – Privacy Shield compliance
When Arxan is a data processor
Arxan collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of Arxan’s Clients and would no longer like to be contacted by one of Arxan’s Clients, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Arxan acknowledges that you have the right to access your personal information. Arxan has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to Arxan’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.
We will not intentionally collect or maintain, and do not want you to provide, any information regarding your medical or health condition, age, race or ethnic origin, political opinions, or religious beliefs or other sensitive information.
Children’s Online Privacy Protection
Our services are not designed for or directed to children under the age of 13, and we will not intentionally collect or maintain information about anyone under the age of 13.
- WHAT DO WE USE THIS INFORMATION FOR?
We may use your information to process your service requests, handle orders, deliver products and services, register you for conferences, process payments, communicate with you about orders, provide access to secure areas of the Website, recommend services that might be of interest to you, to personalize your visit to our Website or use of EASE services, and to enable us to review, develop and continually improve the products services and offers we provide online. We also use this information to prevent or detect fraud or abuses of our Website and to enable third parties to carry out technical, logistical or other functions on our behalf.
We use visitor information to send information about our company to visitors and to get in touch with them when necessary. We also use the information we collect to improve the content of our websites and services and as training aides for our employees. If you sign-up for a co-branded conference presented by us and one of our partners, you also may receive information from that partner. Visitors are given the choice at the point when we request their information, except for visitor information which is passively collected.
Financial Information and payment card details
We may ask visitors to enter credit card or account information in order to process orders for services placed with Arxan or its affiliates. Financial information provided via our website is transferred over a secure connection. We collect this information on a transaction-by-transaction basis and will not authorize the release of the information with anyone not directly involved in processing the transaction. This information may be encrypted and stored for logging purposes in accordance with applicable regulatory requirements.
Credit card numbers are used only for processing payments and are not used for any other purposes. When we use third party service providers for credit card processing services we will enter into a written agreement with such third party ensuring appropriate security and confidentiality measures are in place in safeguarding your personal data.
Service, Marketing, and Other Uses of Visitor Information
We may use web visit information to measure interest in and develop our web pages, services and marketing plans, customize the content you view on your web visits and service uses based on your activity and uses on past visits, and administer our Website and services.
We use the visitors’ IP address and device identifiers to help diagnose problems with our servers and services, and to provision and administer our Websites and services.
We use web beacons to count the number of times that our advertisements and web-based email content are viewed. We combine web beacon information with cookies to track activity on our website originating from advertisements and web-based email content.
We have enabled Google Analytics for Remarketing and Google Analytics Demographics and Interests Reporting as described above. If you wish to opt-out of Google Advertising, you may visit www.google.com/settings/ads and under “Ads on Google” and/or under “Google Ads Across the Web”, and click the “Opt out” link.
We use information about EASE Administrators to send them notices and otherwise communicate with them regarding EASE Services and to send them marketing information.
We use the identifiers and other information from mobile devices used by EASE End Users to provide and administer customized EASE services.
We use information you provide to us via telephone calls, email, web forms and other communications to correspond with you about services you may be interested in purchasing, but we will not do so if you are an EASE End User unless you are also an EASE Administrator. If you elect to purchase or otherwise sign up for a service online using a web form, we will use the information to establish your account. Information you submit in writing, such as chat, email, and web form information is archived and may be tied to information that we collect about your web visits and service usage. Your telephone call may be recorded for training purposes and we may enter information you provide via telephone into our systems to use for the purposes described in this paragraph.
- DISCLOSURE OF PERSONAL INFORMATION
Should you breach our terms and conditions or website or service terms, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, such as to comply with a subpoena or other legal process, we may disclose your information to a relevant authority. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. In particular, we may release the information we collect to third parties when we believe it is appropriate to comply with the law, to enforce our legal rights, to protect the rights and safety of others, or to assist with industry efforts to control fraud, spam or other undesirable conduct.
Some of our services or promotions, such as online conferences, may be co-branded and offered in conjunction with another company. If you register for or use such services, both Arxan and the other company may receive information collected in conjunction with the co-branded services.
If Arxan is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.
- OPTING OUT OF COMMUNICATIONS
We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information. EASE End Users may receive push notifications as part of EASE Services; however, these may be disabled by users in their device settings.
- SECURITY OF YOUR INFORMATION
- DATA INTEGRITY
- RIGHT TO ACCESS YOUR PERSONAL INFORMATION
- INQUIRIES OR COMPLAINTS
Notice to California Residents:
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you may request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at: firstname.lastname@example.org