Effective May 25, 2018 

AKTANA PRIVACY POLICY

Aktana, Inc. and its affiliates worldwide (“Aktana” or “we” or “us”) are committed to protecting the privacy of the users (“you” or “user”) of its Internet websites and applications, and the related services we provide through the Internet, in person, through the telephone or through use of electronic communications (individually and collectively, the “Services”).  

This Privacy Policy, together with our Cookie Policy, describes our practices regarding the Personal Data we collect from you when you use the Services.  As used in this Privacy Policy, “Personal Data” means data that allows someone to identify or contact you (for example, your name, address, telephone number and e-mail address) and any other non-public information about you that is associated with or linked to such data.  

If you have any concerns or questions about your privacy or use of our Services, please contact us as provided below in the section “How to Contact Us.”

1.CONSENT.  By submitting Personal Data through our Services, you agree to the terms of this Privacy Policy and you consent to the use of your Personal Data in accordance with this Privacy Policy.

  1. CHANGES TO THIS PRIVACY POLICY.  This Privacy Policy is subject to occasional revision. We encourage you to visit this page regularly to view our current Privacy Policy, which will indicate the date of the last change. If we make any substantial changes in the way we use your Personal Data, we will notify you by prominently posting notice of the updated Privacy Policy on this page, together with its effective date, and will notify users as required by law.  Continued use of our Services, after we have posted changes on this page and with a new effective date shall indicate your acknowledgement of such changes and your agreement to be bound by the terms and conditions of such changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us and you should cease further use of our Services.  
  2. CHILDREN UNDER 13.  Children under the age of 13 should not send us Personal Data. We do not knowingly collect any Personal Data from children who are under the age of 13. If we become aware that an individual under the age of 13 is submitting information to us, we will attempt to delete the information as soon as possible.
  3. CONSENT TO INTERNATIONAL TRANSFERS OF INFORMATION.  Your Personal Data may be processed in the country in which it was collected and in other countries or jurisdictions that may not have the same data protection laws, or provide as much protection to Personal Data, as the country where you reside. By using the Services, you consent to the transfer and storage of your Personal Data to any other country in which we or our service providers maintain facilities.
  4. TYPES OF DATA WE COLLECT.  We collect both Personal Data and Anonymous Data from you when you use our Services or when you send us information or communications.   “Anonymous Data” means data that is not associated with or linked to Personal Data and does not permit the identification of individual persons.  We collect Personal Data and Anonymous Data, as described below.

5.1 Personal Data You Provide to Us.  If you provide us feedback or contact us via e-mail or through our Services (e.g., in response to a posted employment opportunity), we will collect your name and e-mail address, as well as any other content included in the feedback or e-mail, in order to send you a reply.  When you participate in one of our surveys, request information or establish an account with us, we may collect additional profile information.  We do not collect your name, address, telephone number, e-mail address or other contact information unless you choose to provide that information.

5.2 Personal Data Collected through Technology.  Our computer systems (or those of our service providers) may electronically collect information about you when you use our Services.  The information collected may be machine generated and may include, for example, the domain name of your Internet provider, your browser type, time zone, language, operating system, date of the visit, URL of the last webpage visited before visiting our Website, and URL of the first page you visit after leaving our Website, pages viewed, time spent on a page, click through and clickstream data, queries made, search results selected, history, or comments made.  When we send you an electronic communication, such as an e-mail, we may collect certain information, such as the action taken upon receipt of the e-mail (for instance, whether you opened or deleted the e-mail).

Our Services use cookies and similar technologies (e.g., web beacons, pixels and device identifiers) to store on a user’s computer or device information about the user’s identity and preferences and settings, to gather statistical information about the use of our Services, to improve the design and functionality of our Services. Please review our Cookie Policy for further information about how we use cookies and how you can disable them.

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of our Services, and report on the activities and trends. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners.  You may opt-out from the collection of your information by downloading the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout.

5.3 Personal Data Collected from Third Parties.  We may obtain information from third parties with whom we do business, such as in connection with a trade show or webinar or through public databases, social media or joint marketing partners. 

  1. USE OF YOUR DATA.

6.1 General Use.  We use Personal Data collected from users for the following purposes:

  • To provide the Services requested by a user.
  • To respond to user questions and other requests for information made through the Services.
  • To forward administrative information to the user.
  • To send marketing information, invitations to events or other communications that we believe may be of interest to the user.
  • To keep records of contact information and correspondence.
  • To remember a user’s preferences, such as language, font size and communication type, and the user’s interests regarding subject matter.
  • To personalize a user’s online experience, including the provision of content addressing a user’s preferences or interests and expediting the processing and completion of a transaction.
  • To administer our Services, diagnose technical problems, and otherwise manage our business.
  • To allow a user to navigate or browse through our Services more quickly and efficiently.
  • To determine the approximate location of each user, calculate usage levels, diagnose server problems, and in general to administer the Services, in each case through use of a user’s IP address.
  • To improve, enhance or modify our business and the Services through data analysis, audits, security and fraud monitoring and prevention.
  • To aggregate information and create Anonymous Data, as described below.
  • To perform other functions or processes described to the user at the time of collection of the Personal Data.

6.2 Creation of Anonymous Data.  We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you.  We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve site navigation.  We reserve the right to use and disclose Anonymous Data to third parties for research, analytic or strategic purposes.

6.3 Feedback.  If you provide us with feedback on any of our Services, we may use such feedback for any purpose.  We will treat the Personal Data in such communication in accordance with this Privacy Policy.

  1. DISCLOSURE OF YOUR PERSONAL DATA.

7.1 Affiliates.  We may share some or all of your Personal Data with our current and future subsidiaries, parent companies, or other companies that control or are under common control with us (our “Affiliates”), provided we require our Affiliates to honor this Privacy Policy.  We also may share your Personal Data with our offices throughout the world, including in the United States, Europe and Asia. 

7.2 Change in Control or Sale.  We may transfer users’ Personal Data to a successor entity in the event of a sale, merger, transfer or other disposition of all or any portion of our business, assets or ownership, or other change in control. Except as otherwise provided by a bankruptcy or other court, the use and disclosure of all transferred Personal Data will be subject to policies that are consistent with the policies described in this Privacy Policy. However, any information that a user submits or that is collected after that transaction may be subject to the privacy policy adopted by the successor entity.

7.3 Legal Requests and Prevention of Harm.  We may use, share or disclose information about users, including your Personal Data, in order to address legal concerns or liabilities, particularly when we believe that a user has violated the Terms of Use of our Services or otherwise misused our Services, such as to gain unauthorized access to any system, to engage in spamming activities, to engage in denial of service or similar attacks, or to conduct any fraudulent or unlawful activity.  We also may be required to provide legal authorities access to a user’s information, in accordance with applicable law, including laws outside the user’s country of residence.

7.4 Disclosure to Third Party Service Providers.  Except as otherwise stated in this policy, we do not generally sell, trade, share, or rent the Personal Data collected from our Services to other entities.  However, we may share your Personal Data with third party service providers to provide you with the Services; to conduct quality assurance testing; to facilitate creation of accounts; or to provide technical support. These third party service providers are contractually required not to use your Personal Data other than to provide the services we request.  You expressly consent to the sharing of your Personal Data with our third party service providers for the sole purpose of providing the Services.

7.5 Disclosure for Direct Marketing Purposes.  We currently do not share Personal Data with third parties for their direct marketing purposes without the express consent of the user.

7.6 Social Media.  The Services may provide links to third party social media services (e.g., LinkedIn and Facebook) where a user is able to post comments.  These third party services may collect, retain and share information about a user, and use of such third party services is subject to the terms and conditions of their privacy policies.  Please note that any information that is posted or disclosed through social media may be available to us, to other users of that service or to the public.  We recommend caution when using these features.

7.7 Third Party Links.  The Services may contain links to third party websites to provide additional information or for the purposes of communication with such third parties.  We are not responsible for the privacy policies of those third parties, and strongly encourage you to read and understand their privacy policies.

  1. YOUR CHOICES REGARDING YOUR PERSONAL DATA.

8.1 Opt Out From Communication.   We may periodically send you free newsletters and e-mails that directly promote the use of our Services and potentially those of our marketing partners.  When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below).  Despite your indicated e-mail preferences, we may send you notices of any updates to our Terms of Use or Privacy Policy.

8.2 Changes to and Deletion of Personal Data.  You may request that we change or delete any of your Personal Data in your account by sending an e-mail to us at the e-mail address set forth below.  However, we may be required (by law or otherwise) to retain this information and not delete it (or to retain this information for a certain time period, in which case we will comply with your deletion request only after we have fulfilled such requirements).  In regions where there is a right to erasure (right to be forgotten) with respect to your Personal Data, we will use all reasonable efforts to delete such Personal Data without undue delay. When we delete any information, it will be deleted from the active database, but may remain in our archives.

  1. SECURITY OF YOUR PERSONAL DATA.   We use a variety of technical, organizational and administrative measures to protect user information that we possess against unauthorized or unlawful access or processing, and against accidental loss, destruction or damage, We believe that these measures are reasonably adapted to the  nature and types of information in our custody,  However, even though we take reasonable efforts to protect the information in our custody, no transmission over the Internet and no data storage or security system is fully secure.  Therefore, we cannot guarantee the security of any information that we may receive from you or transmit to you.
  2. RETENTION OF YOUR PERSONAL DATA. We retain information about users or as long as necessary to perform the activities described in this Privacy Policy and to comply with our legal obligations. We may need to retain certain information for record keeping purposes or for completing a transaction that you commenced prior to requesting a change or deletion.  In addition, it is likely that residual information may remain within our databases, back-ups or other records, and not be fully removed.
  3. DO NOT TRACK SIGNALS. Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing on the Internet. The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Consequently, due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated Do Not Track signals in response to the laws of California or any other jurisdiction.
  4. CONTACT INFORMATION.  We welcome your comments or questions regarding this Privacy Policy.  Please e-mail us at privacy@aktana.com. If you prefer to contact us by mail, please use the following address:

If you are located in the European Union or United Kingdom:

Building 1, Spaces, Chalfont Park, Gerrards Cross, Buckinghamshire, SL9 0BG, United Kingdom

If you are located in any country other than the countries listed above:

Aktana, Inc., Attn: Data Protection Officer, 207 Powell Street, Suite 800, San Francisco, CA 94102, USA

  1. DISPUTE RESOLUTION.If you believe that we have not adhered to this Privacy Policy, please contact us by email at privacy@aktana.com.  We will do our best to address your concerns.  If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.

This Privacy Policy was last revised on May 25, 2018.

 

COOKIE POLICY

We use cookies, which are small text files placed on your computer or mobile device when you visit our Services to better enable their features and functionality.  By using our Services, you consent to our use of cookies as described in this Cookie Policy. Please note that third party websites that you may be directed to may use their own cookies.

We use two types of cookies:  persistent cookies and session cookies. 

A persistent cookie helps us recognize you as an existing user, so it is easier to return and interact with our Services.  After you accept our Cookie Policy, a persistent cookie stays in your browser and will be read by our Services when you return.

A session cookie is temporary and enables you to move from page to page on our Services and allows information that you enter to be remembered during your session using the Services. A session cookie is deleted when you close your browser or after a short period of time.

If you do not want cookies placed on your computer or mobile device, you can adjust the setting of your Internet browser to reject some or all cookies and to alert you when a cookie is placed on your device.  However, if you adjust the setting to reject all cookies, some features and functionalities of our Services may be blocked or adversely affected.

While adjusting your browser setting can prevent the future placement of cookies, it does not remove existing persistent cookies.  You can manually remove previously stored persistent cookies by following Internet browser help file directions.

You can find additional information about cookies, including information about adjusting Internet browser settings and deleting cookies, at www.allaboutcookies.org.

Cookies are used in the following ways on our Website:

Website statistics and analysis. We utilize statistical services, such as Google Analytics, to review how visitors use our Services. This information helps us improve navigation through our Services and the content we offer. Google and other service providers use cookies as part of this process to collect anonymous information, including the number of visitors to our Services, how visitors are accessing our Services, the pages they visit and the length of time they spend on our site.

Contact Us page. We use a session cookie on this page to allow you to contact us via the Website.