Privacy Notice

Privacy Notice

Effective: 06, 13, 2019

 

Overview

What Information Do We Collect?

  1. Information You Share With Us
  2. Information Collected Automatically
  3. Information Obtained From Third Parties

How Do We Process Personal Data?

  1. Operational Uses
  2. Marketing Uses
  3. Sharing of Personal Data

Protecting Personal Data

Retention of Personal Data

Your Rights Regarding Personal Data

  1. Accessing, Modifying, Rectifying, and Correcting Collected Personal Data
  2. Your California Privacy Rights

Your Choices

  1. Communications Opt-Out
  2. Cookies, Web Tracking, and Advertising

Other Important Information About Personal Data and the Services

  1. Collection of Personal Data from Children
  2. Third-Party Websites and Services
  3. Business Transfer
  4. Do Not Track
  5. International Use

Modifications and Updates to this Privacy Notice

Applicability of this Privacy Notice

Additional Information and Assistance

  1. 1. Overview

    CSC Partners, LLC and its affiliates (collectively, “TalkBackTime,” “we,” “us,” “our”) respect your privacy and are committed to protecting the personal data we hold about you. If you have questions, comments, or concerns about this Privacy Notice or our processing of personal data, please see the bottom of this Privacy Notice for information about how to contact us.

    This Privacy Notice explains our practices with respect to personal data we collect and process in connection with your relationship with us. This includes information we collect through, or in association with, our website with a home page located at www.talkbacktime.com, our related social media pages or sites, or otherwise through your interactions with us relating to the foregoing, (collectively, the “Services”).

    Please note, however, that this Privacy Notice only covers the personal data we process about our customers and visitors to the Services. Our customers may use our Services as a platform to create questionnaires and surveys and collect, process, and share videos and personal data; when they do this, they control what personal data they collect, how it is processed, and to whom it is disclosed. As a result, you should consult the applicable customer’s privacy policy for more information about how and for what purposes they collect and process personal data.

    Please review the following to understand how we process and safeguard personal data about you. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing personal data to us in connection with the Services, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.

  2. 2. What Information Do We Collect?

    We collect a variety of personal data from and about you through the Services, including:

    • When you provide it to us directly, such as when you sign up for a user account through the Services or place an order for Services;
    • Automatically through logging and analytics tools, cookies, pixel tags, and as a result of your use of and access to the Services; and
    • From third-party sources, including service providers such as our analytics providers and through your interactions with us on social media websites.

    You have choices about certain information we collect. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide any aspect of our Services, you may not be able to use those Services. In addition, as noted below in the section captioned “Your Choices” it is possible to change your browser settings to block the placement of cookies and/or the automatic collection of certain information.

    Finally, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.

    Information You Share With Us. We collect personal data from you when you provide it to us, including when you sign up for a user account through the Services, place an order for services, upload or post content or questionnaires that include personal data about you, or contact us with questions or comments.

    • Account Registration. When you sign up for a user account on the Services, you must provide us with your name, email address, username and password, employer or organization upon whose behalf you use the Services (if any), and any other information you may choose to optionally provide, such as telephone number.
    • Orders. If you sign up for or purchase a subscription through the Services, you must provide us with information to process that request and/or enter into a contract with you (including but not limited to your account information and payment and billing information (billing address, credit card or other payment information).
    • Email Notifications. In addition, you can choose to sign up for email notifications about us through the Services by providing us with your email address.
    • Other Information You Provide. If you contact us with questions, requests, or complaints, or to exercise your legal rights, we collect personal data sufficient to answer your questions, address your requests, and/or handle your complaints, as applicable. In certain situations, we may also require you to provide personal data to authenticate your identity in order to carry out your requests.

    We also collect information from you that, depending on applicable law, may not constitute personal data.

    Information Collected Automatically. When you browse or use the Services, we utilize commonly-used logging and analytics tools, including Google Analytics, to collect information about your device, the network used to access the Services, and information about your use of the Services (such as how you navigate and move around the Services).

    Information collected automatically includes the software and hardware attributes of the device you use to access the Services, unique device ID information, regional and language settings, performance data about the Services, network provider, and IP address (a number assigned to your device when you use the Internet). In addition, information is collected passively in the form of log files and third-party analytics that record website activity. For example, log file entries and analytics data are generated every time you visit a particular page on our website, and track the dates and times that you use the Services, the pages you visit, the amount of time spent on specific pages, and other similar usage information, and general data (including the name of the web page from which you entered our website).

    • Cookies, Web Tracking, and Advertising. We, and service providers on our behalf, use cookies and pixel tags that allow us and our service providers to store information locally on your device, identify your device, track your interactions with other sites or with our email campaigns, and track activity over time and across websites.

    These tracking technologies allow us to personalize and enhance your experience in regard to our Services, to collect data about your visit to our Services, to help diagnose problems with our servers, to administer the Services, to evaluate the effectiveness of our marketing and advertising campaigns, to permit analytics providers to gather information about your visit to the Services, and to gather broad demographic information about our users.

    Consult the “Your Choices” section below for information about how you can reject, delete, or prevent cookies from being placed on your system; and how you can opt out of, limit, or prevent certain web tracking technologies from collecting information about you or your use of the Services.

    Information Obtained from Third Parties. We receive personal data from third parties that we have engaged to provide services to us, as well as from third parties that provide web analytics and usage information to us such as Google Analytics.

    In addition, if you choose to interact with us or our partners on social media by posting to our pages, tagging us (or using certain hashtags or other identifiers) in posts, or participating in activities, we may collect certain information from the social media account you use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and understand and engage with our audience.

    For the purposes of this Privacy Notice, “partners” means affiliates, service providers, licensors, vendors, manufacturers, distributors, or other third parties with which we have a business relationship.

  3. 3. How Do We Process Personal Data?

    We process personal data for two general purposes, pursuant to various legal bases:

    • For our business operations (including communicating with you, providing the Services and subscriptions, authenticating your account, providing information about our products and services, improving the Services, and complying with applicable legal requirements); and
    • To market and promote our, and our partners’, products and offerings.

    We disclose personal data to our service providers to allow them to provide services to us and to you and to assist in carrying out your requests, and to our partners in aggregate, demographic form in connection with our marketing and business development efforts.

    In addition, we may disclose information we maintain, including personal data: when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others.

    See the “Your Choices” section below for information about how you can make decisions about how we process personal data, including how to opt out of certain marketing communications.

    Operational Uses. We process your personal data as part of our operations, which include:

    • Providing you with information tailored to your requests, responding to inquiries, and delivering services;
    • Operating, maintaining, and improving the quality of the Services and such content, products and/or services as we may make available through the Services;
    • Communicating with you by email, mail, text message (SMS, MMS), telephone, push notification, and other methods of communication, in each case with your consent, if such consent is required in accordance with applicable laws, about the Services, your account, and other related topics;
    • Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies;
    • Endeavoring to protect our and our partners’ rights, property, or safety, and that of our users and other parties; and
    • For other purposes, as permitted or required by law.

    Marketing Uses. We process your personal data to send messages to you about us, our partners, and the products and services we and our partners offer, which may from time to time include contests, rewards, events, and special offers for products and services. These communications will only occur with your prior consent, if such consent is required in accordance with applicable laws; for example, we will not call you or send you text messages for marketing purposes unless you both consent to receive such communications and provide us with your telephone number.

    We process personal data collected through social media platforms and web tracking technologies to market to and understand our audience.

    Sharing of Personal Data. Some of the above processing involves sharing collected personal data with third parties, including service providers, affiliates, and other partners.

    • We share personal data with third parties when you ask us to do so;
    • We share personal data among our affiliated entities;
    • We share personal data with our service providers for business purposes, including payment processors, software and Web developers, hosting services, commercial email providers, security consultants, and other vendors we engage so that they may provide services to us or on our behalf;
    • We may share personal data we collect in aggregated, demographic form with certain partners, prospective partners, and service providers in order to provide us and/or our affiliates and partners with information about the use of the Services and levels of engagement with the Services, to allow us to enter into new business relationships, and to allow us to market products or services on their behalf; and
    • We share personal data with third parties when we believe it is required by, or necessary to comply with, applicable law, or when we believe it is reasonably necessary to protect our and our partners’ rights, property, or safety, and that of our users and other parties.
  4. 4. Protecting Personal Data

    We employ commercially reasonable physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data.

    However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmissions are not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

  5. 5. Retention of Personal Data.

    We retain personal data to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties. Please contact us as provided below if you have questions about our data retention practices.

    In addition, please note that the retention period of personal data you may collect on your own behalf through the Services may be limited by the terms of the subscription you purchase.

  6. 6. Your Rights Regarding Personal Data

    You have a variety of legal rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us as provided at the end of this Privacy Notice, or by following instructions provided in this Privacy Notice or in communications sent to you. Please be prepared to provide reasonable information to identify yourself and authenticate your requests.

    Note, however, that we may request certain reasonable additional information (that may include personal data) to help us authenticate the request and/or to clarify or understand the scope of such requests.

    These rights vary depending on the particular laws of the jurisdiction applicable to you, but may include:

    • The right to know whether, and for what purposes, we process personal data about you;
    • The right to be informed about the personal data we collect and/or process about you;
    • The right to access, modify, and correct personal data about you (as set forth in more detail below under “Accessing, Modifying, Rectifying, and Correcting Collected Personal Data”); and
    • The right to know with whom we have shared personal data about you, for what purposes, and what personal data has been shared (including whether personal data was disclosed to third parties for their own direct marketing purposes).

    Accessing, Modifying, Rectifying, and Correcting Collected Personal Data. We strive to maintain the accuracy of any personal data collected from you, and will use commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and notify us as soon as possible of any updates or corrections.

    In accordance with applicable law, you may obtain from us certain personal data in our records. If you wish to access, review, or make any changes to personal data you have provided to us through the Services, you may do so at any time by contacting us as provided below or, for certain information, through your account on the Services. Please note, however, that we reserve the right to deny access as permitted or required by applicable law.

    Your California Privacy Rights. In addition to the above-listed rights, California privacy law provides individuals with enhanced rights in respect of their personal data.

    • Shine the Light. California Civil Code Section 1798.83, known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge.

      We do not disclose personal data protected under the Shine the Light law to third parties for their own direct marketing purposes.

  7. 7. Your Choices

    In addition to your choices with respect to the collection of personal data (see “What Information Do We Collect?” above), and any rights you may have that provide you with choices or control over certain processing of personal data, you have the ability to make certain choices about how we communicate with you, and how we process certain personal data.

    Communications Opt-Out. You may opt out of receiving marketing or other communications from us at any time through a given communications channel by following the opt-out link or other unsubscribe instructions provided in any message received, or by contacting us as provided at the end of this Privacy Notice.

    Note that if you do business with us in the future, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g., e-commerce, password reset communications, etc.).

    Cookies, Web Tracking, and Advertising. Most browsers automatically accept cookies by default, but you can adjust your device and/or browser settings to delete and/or block some or all cookies, or provide notifications when you receive a new cookie. Consult the “Help,” “Tools,” or “Preferences” menus on your browser, or the documentation for your device, for more information about how to do this. Please note, however, that blocking or deleting certain cookies may negatively affect your user experience.

    If you wish to opt out of Google Analytics tracking, visit https://tools.google.com/dlpage/gaoptout. You may also disable tracking for certain analytics providers by removing or blocking related cookies or similar technologies.

  8. 8. Other Important Information About Personal Data and the Services.

    Our Privacy Notice also includes information about other practices with respect to personal data, including:

    • Collection of personal data from children;
    • Links and references to third-party websites and services on our Services:
    • What happens to personal data in the event we sell or transfer some or all of our business;
    • How we respond to “Do Not Track” requests; and
    • Information about where we process and transfer personal data.

    Collection of Personal Data from Children. Children under 16 years of age are not permitted to use the Services, and we do not knowingly collect information from children under the age of 16. By using the Services, you represent that you are 18 years of age or older, or are 16 years of age or older and have valid parental consent to do so.

    Third-Party Websites and Services. As a convenience, we may reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, partners, and third parties with which we do business. When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access these third-party services at your own risk. This Privacy Notice does not apply to any third-party services; please refer to the Privacy Notices or policies for such third-party services for information about how they collect, use, and process personal data.

    Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.

    Do Not Track. We use analytics systems and providers that process personal data about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.

    Note, however, that you may find information about how to opt out of Google Analytics, and/or block or reject certain tracking technologies in the “Your Choices” section above.

    International Use. Your personal data will be stored and processed in the United States. If you are using the Services from outside the United States, by your use of the Services you acknowledge that we will transfer your data to, and store your personal data in, the United States, which may have different data protection rules than in your country, and personal data may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities in the United States.

  9. 9. Modifications and Updates to this Privacy Notice

    This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice.

    We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this Privacy Notice, such as by posting a notice on the Services or sending you an email. Your continued use of the Services following our posting of any revised Privacy Notice will constitute your acknowledgement of the amended Privacy Notice.

  10. 10. Applicability of this Privacy Notice

    This Privacy Notice is subject to any agreements, including the Terms of Use, Acceptable Use Policy, and any other agreements, documents, or policies that govern your use of the Services. This Privacy Notice applies regardless of the means you use to access or provide information through the Services, except that it does not apply to the provision of personal data in response to any survey or questionnaire made available on the Services by or on behalf of a party other than us.

    This Privacy Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.

  11. 11. Additional Information and Assistance

    If you have any questions or concerns about this Privacy Notice and/or how we process personal data, or would like to exercise any of the legal rights set forth above, please contact us at:

    TalkBackTime
    CSC Partners, LLC
    2101 L ST, NW, Suite 800
    Washington, DC 20037
    info@talkbacktime.com

    For questions or comments about an existing TalkBackTime account, please contact support@talkbacktime.com.