Last Updated: July 29, 2020
2. COLLECTION OF INFORMATION
The categories of personal information we collect depend on whether you are a user of Sesh sessions, Sens, or Polyboards, a visitor to our website, and the requirements of applicable law.
(a) information you provide directly to us when using the services
Account creation and registration.
All Sesh products
Sign up. When you first sign up for information about our Services, we collect your email address, as well as optional information, such as you name and position, company, employee count, and company web address.
Profile creation. To register, we require your name an email address. You can also upload optional information to your profile, such as your company, job title, LinkedIn URL, your preferred pronouns, and other similar demographic information.
Payment information. To process payments, our service providers will process your mailing address and payment information.
To facilitate in-person training sessions, we will collect additional contact information, such as the location of the session. We also store audio and video of each training session.
As part of the Service, we will receive videos you share with us, along with any information you provide regarding the context of the conversation. We will also collect biometric identifying information required to perform decision state analysis on the video’s subject.
IMPORTANT NOTE regarding biometric information: You may use the Empath service to analyze videos of a person or people (“subjects”) only if you have first obtained their explicit, prior consent (or the consent of their legal representative or guardian). By uploading video to our Services, you agree that we may collect the subject’s facial geometry or “faceprint” in order to perform decision state analysis for disclosure to you. The subject’s faceprint will be used only to identify the subject and perform the decision state analysis, and any biometric identifying information will be accessible only to Sesh internal staff. We do not sell, lease, trade, or otherwise profit from biometric data; provided, however, that we and our vendors may be paid for your use of the Services that utilize such biometric data. We delete all biometric identifying information immediately upon completing the decision state analysis.
Bluetooth-enabled models of the Polyboard will collect Bluetooth identifiers of other devices you own, in order to allow you to use the Polyboard as an external display and input device.
Your communications with us. We may collect additional information from you when you request customer support, or otherwise communicate with us. This information may include your contact information, and any other information you choose to provide.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
(b)Information About Your Interactions with the Services
We may collect additional information from you when you complete a quiz, questionnaire or other form, participate in any interactive features of the Services, including any video or audio call features we provide.
In addition to the information above, you may provide us additional information to help us identify the right session(s) for you, or in conjunction with your attending sessions. For example, you may provide information about your title, employment details, language, gender, marital status, nationality, or other information about you and your personal or professional experiences. We also collect information about your use of the Services, such as how often you use the Services, development programs planned and attended, engagement status, and session ratings.
(c)Information We Collect Automatically When You Use the Services
When you access or use the Services, we automatically collect information about you, including the following:
Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, general location information (derived from IP address), and the page you visited before navigating to the Services.
Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, MAC address, operating system and version, unique device identifiers, and mobile network information.
Information Collected by Cookies and Other Tracking Technologies: We use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and, understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Your Choices” below.
Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Information We Collect from Other Sources: We may also obtain information from other sources, such as list providers and publicly available sources, and combine that with information we collect through the Services. We also may receive information about you from the coaches with whom you interact through the Services.
USE OF INFORMATION
We may use the information we collect for a variety of business purposes, to provide, maintain, and improve the Services, including to assess and improve the quality of our Services. We may also use the information we collect to:
Provide and deliver the products and services you request, process transactions, and send you related information;
Verify your identity and, if applicable, authorization for you to use the Services (such as from your employer);
Respond to your comments, questions, and requests;
Send you technical notices and other administrative messages;
Communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;
Monitor and analyze trends, usage, and activities in connection with the Services;
Conduct research, analysis, and surveys;
Improve, upgrade or enhance our Services;
Identify and repair errors that impair existing intended functionality;
Perform audits relating to interactions, transactions and other compliance activities;
Personalize and improve the Services and provide content or features that match user profiles or interests; and
Carry out any other purpose for which the information was collected.
Automated profiling. We may use technologies considered automated decision making or profiling. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology. You may escalate any concerns you have by contacting us below.
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.
SHARING OF INFORMATION
We have not sold users’ personal information in the preceding 12 months. We do not share personal information with third parties, except as provided below.
When you use the Services, we may share information about you with our leads so that they can provide services to you. We may also share information relating to your use of the Services with the employer or other entity who has sponsored your use of the Services, such as the program you selected and how you used the Services (such as the number of sessions you attended).
The categories of personal information shared with third parties as part of our business include:
With vendors, consultants, and other service providers who need access to such information to carry out work on our behalf, such as IT and related services; information and services; payment processors; customer service providers; and vendors to support the provision of the Services;
In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of you, us, or others;
In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company; and
With your consent or at your direction, including if we notify you through the Services that certain information you provide will be shared in a particular manner and you provide this information.
Advertising Partners. Through our Services, we may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information from your user profile (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you within our services and when you visit third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
We store the info we collected about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
● SECURITY OF YOUR INFORMATION
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information, unless we have a legal obligation to retain it, and terminate the child’s account.
You may update, correct or delete information about you at any time by contacting us at firstname.lastname@example.org. Please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.
You may opt out of receiving promotional communications from us by following the instructions in those communications, or by emailing us email@example.com. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.
Mobile Push Notifications/Alerts
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device. “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
YOUR PRIVACY RIGHTS
In accordance with applicable law, you may have the right to:
Access to/Portability of Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.
Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.
Request Deletion of your personal information, subject to certain exceptions prescribed by law.
Request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request, such as by asking you questions related to the use of your account.
You have the right not to be subject to discriminatory treatment as a result of your exercise of the above rights.
Legal Basis for Processing
If you are a European Resident, when we process your personal data we will only do so in the following situations:
We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested).
We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
You have provided consent for us to process your personal data.
If you are a European Resident and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm
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