Privacy Policy of Apperian, Inc.

INTRODUCTION

Protecting personally identifying information is a core Apperian value. This Privacy Policy describes how Apperian collects and uses the personally identifying information you provide on our Web sites and in certain other ways. It also describes the choices available to you regarding Apperian’s use of your personally identifying information and the steps you can take to access this information and to request that we correct or delete it.

Apperian, Inc. complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Apperian, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Apperian’s certification, please visit http://www.export.gov/safeharbor/

We self-certify compliance with

If you have questions about this Privacy Statement or want to contact us regarding how we handle your data, please send an email to privacy@apperian.com or write to us at:

Apperian, Inc.
321 Summer St.
Boston, MA 02210

By visiting Apperian websites or otherwise providing your personal information to Apperian via any other means, you are accepting and consenting to the practices described in this Privacy Statement.

For purposes of this Privacy Statement, the term “visitor” includes visitors to our websites who are not yet customers, those who become customers, as well as those who do not become customers; whether you upload information to our websites, download it, or are merely visiting our websites. You can choose not to provide certain information when using our websites but then you might not be able to use all features.

As to 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”.

1. WHAT DO WE COLLECT AND WHERE?

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.

Generally, we may collect information about you when you provide your personal information to us via email or other written correspondence, telephone calls, web based forms, or other means, or we may use automated technical means to collect information about all website visitors, for example, by use of cookies. If you are an EASE End User and you access EASE Services from a compatible mobile phone or other device, we may also collect information about you (for example, your device identifier and other information about your EASE use).

Web Visit

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.apperian.com, ease.apperian.com, blog.apperian.com, www.apperian.net.

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.

When you visit our Website, our server logs your IP address (unique network addresses), the time and duration of your visit, and the time and duration of the pages on our website you view. If you arrive at our website by clicking a paid advertisement (including a paid search engine result) or a
link in an email, then we will capture information that tracks your visit from that link. If you arrive at our Website by clicking a non-paid source, such as link in a non-paid search engine result or an unsponsored link on another website, we may capture information that tracks your visit from that source to the extent we are able to do so. We may also capture information about your computer system, such as your browser type and operating system.

We will likely place a cookie on your hard drive during the web visit. A cookie is a unique alphanumeric identifier that we use to help us identify the number of unique visitors to our Website, whether or not those visitors are repeat visitors, and the source of the visits. Cookies cannot be executed as code or used to deliver a virus. Other servers cannot read them and personal information cannot be gathered from them. They are simply an identifier shared between you and us to allow us to improve the services we offer to you through our Website. If you do not wish cookies to be placed on your computer, then they can be disabled in your web browser. The option to do so is normally found in your browser’s “security settings” section. However, please note, permanently disabling cookies in your browser may hinder your use of our Website as well as other websites and interactive services.

A web beacon, also known as a web bug, is a small graphic (usually 1 pixel x 1 pixel), that is embedded in a web advertisement, email, or page on our web site, but is invisible to you. When you view a page on our web site, an email or an advertisement your web browser will request the web beacon from a web server, which in turn will set a cookie in your web browser containing a unique identifier. This unique identifier will be linked to log information that is used to track your movements on our web site in order to determine the effectiveness of content and advertising campaigns.

We do not collect personal information about you as part of a web visit, but web visit information may be tied to other information (including personal information) we collect from you via web forms and the other means we describe in this Privacy Statement.

Links to non-Apperian Websites

We may provide links to third-party websites for your convenience and information. The privacy practices of those sites may differ from Apperian practices and are not controlled by Apperian and covered by this Privacy Statement. We do not make any representations about third-party websites. We encourage you to review their privacy policies before submitting your personal data.

Personal information received from the EU

When Apperian is a data controller – Safe Harbor compliance

Apperian adheres to the Safe Harbor Principles (Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement) as described in this Privacy Statement, with respect to the personal data we collect from EU data subjects or receive from our affiliates located in the EU, such as information regarding service requests, service orders, handling orders, delivering services and processing payments; and have certified our compliance with the Safe Harbor Framework to the United States Department of Commerce. Apperian Safe Harbor certification can be found at https://www.export.gov/safehrbr/list.aspx.

When Apperian is a data processor

Apperian’s obligations with respect to personal data for which Apperian is solely a data processor, such as personal data that Apperian’s customers store or transfer using EASE Services or Apperian’s other technology hosting services, are defined in its agreements with its customers and are not included in this Privacy Statement. In those circumstances Apperian receives personal data from the EU as an agent of the customer merely for processing and is not required to apply Safe Harbor principles to that information. The customer will remain responsible for the personal data that it collects and processes and for the compliance with applicable data protection laws.

Sensitive Information

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.

2. WHAT DO WE USE THIS INFORMATION FOR?

Personal Information

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.

Contact Information

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 Apperian 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 cookies to help us recognize visitors as unique visitors when they return to our websites. We may also use the cookie to discover whether a certain visitor has visited our site more than once, and the source for each visit. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our Website and count the number of anonymous users of our sites.

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 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 on devices used by EASE End Users to provide and administer 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.

3. DISCLOSURE OF PERSONAL INFORMATION

Personal information we gather is for internal use only and we will not authorize the release of this information to anyone outside Apperian (except (a) to third party service providers to Apperian who perform functions on our behalf but in such event personal information will only be shared to the extent reasonably necessary to perform their functions and they will not be authorized to use it for any other function, and (b) to certain other third parties, as described in this Privacy Policy), unless you have consented to such disclosure.

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, 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.

We may release the information we collect to third parties, where the information is provided to enable such third party to provide services to us, provided that the third party has agreed to use at least the same level of privacy protections described in this Privacy Statement, and is permitted to use the information only for the purpose of providing services to us.

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 Apperian and the other company may receive information collected in conjunction with the co-branded services.

We may release the information we collect to a third party who, directly or indirectly, buys or obtains control of substantially all of the assets or stock of Apperian, Inc., or of the line of business that has your information, provided that the third party has agreed or is otherwise obligated to use at least the same level of privacy protections described in this Privacy Statement.

4. OPTING OUT OF COMMUNICATIONS

Apperian gives you an opportunity to chose to opt-out of personal data being disclosed to third parties for a purpose incompatible with the purpose for which it was originally collected, except for the purposes described in section 3 (Disclosure of Personal Information) of this Privacy Statement, including your opting out of receiving future marketing mailings. We will not use your contact information to correspond with you about our services if you ask us not to, unless you are an EASE Administrator. Please send your request to privacy@apperian.com or write us at Compliance Officer, Apperian, Inc., 321 Summer Street, Boston, MA 02210. It may take up to ten days to remove your contact information from our marketing lists, so you may receive correspondence from us for a short time after you make your request.

5. SECURITY OF YOUR INFORMATION

Apperian is committed to using commercially reasonable industry practices regarding security measures to prevent the loss, misuse and alteration of the information in our possession. We use various security measures to protect the information we collect, as appropriate to the type of information, including encryption, firewalls, and access controls. We store information you provide to us on a computer system located in a controlled facility with a limited access. Visitor textual information is encrypted during transmission, our company databases are accessible only by Apperian employees, contractors and agents on a need to know basis and who have entered into and are bound by a confidentiality and nondisclosure agreement with Apperian.

6. DATA INTEGRITY

Personal data we collect is relevant for the purposes for which it is to be used. Apperian takes reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current.

7. RIGHT TO ACCESS YOUR PERSONAL INFORMATION

If you believe that any personal information we have about you is incorrect, or is, has been, or might be used inappropriately, please contact us at privacy@apperian.com, and we will take steps to correct or delete the information, or restrict its use, as appropriate.

8. VERIFICATION

Apperian utilizes the self-assessment approach to assure its compliance with its Privacy Statement. Apperian regularly verifies that the privacy statement is accurate, comprehensive, prominently displayed, completely implemented and in conformity with the Safe Harbor Principles and conducts its self-assessment on an annual basis to ensure that all relevant privacy practices are being followed. Appropriate employee training is in place and internal procedures for periodically conducting objective reviews of compliance are in place. A statement verifying this self-assessment is signed by a corporate officer or other authorized representative at least once a year.

9. INQUIRIES OR COMPLAINTS

If you have a question or complaint about this Privacy Statement or our information collection practices, please contact us at privacy@apperian.com or write us at Compliance Officer, Apperian, Inc., 321 Summer St., Boston, MA 02210. We will investigate the matter and are committed to resolve any privacy concerns that you may have. If your inquiry has not been satisfactorily addressed and you are a visitor located in the EU, you may contact European Data Protection Authorities, elected as a Dispute Resolution in our Safe Harbor self-certification.

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: privacy@apperian.com.

10. CHANGES

Apperian may change this Privacy Statement from time to time by posting a new Privacy Policy on its website. You should check our website to see recent changes, however, we will not materially change our privacy policies and practices described herein to make them materially less protective of personal information collected in the past without your prior consent.

This Privacy Policy was last updated on August 1, 2013.