PRIVACY POLICY

SIFTERY INC
LAST UPDATED: APRIL 6, 2018

Siftery Inc (“Siftery,” “we,” “us,” or “our”) respects the privacy of our clients, their employees, their customers, and others (“Users”) that use Siftery Website i.e., www.siftery.com (“Website”) and the range of data intelligence services that Siftery provides (“Services”). This Privacy Policy (“Privacy Policy”) details Siftery’s information-handling practices with respect to information you provide to us or that we learn from your use of the Website and the Services and tells you how we may collect, use, and in some instances share this information. PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE WEBSITE.

By using our Services, you are consenting to Siftery processing your information as described in this Privacy Policy now and as amended by us. These uses include the collection, storage and deletion, disclosure and transfer of your information to and from the United States to provide you with the Services you have requested.

If you have any questions or comments about our practices or this Privacy Policy, please contact us at privacy@siftery.com.

Capitalized words not defined herein will have the same meaning ascribed to them under our End User License Agreement.

INFORMATION SIFTERY COLLECTS

  • Personal Information: In its course of business, Siftery collects Personal Information from its Users. This information includes contact information, such as their name, company name, address, business contact information, and e-mail address. Siftery does not collect any other Personal Information such as social security number, driver’s license number, credit rating, or other personal financial data.
  • User Information: Users have the opportunity to share various types of information with Siftery and among themselves through use of the Services. Users may share information with us either during the registration process or when subscribing to our periodic newsletters. Siftery provides a variety of data intelligence Services to its Users and Users have the opportunity to upload any materials that may assist Siftery and Users to achieve their requirements. You hereby acknowledge that providing your Personal Information and any other information about you via the Services, is voluntary and this information may be visible to other Users. <> Please be aware that any information that you choose to share on any publicly available portion of the Service or with third parties, including without limitation your personal page, links to social network pages, blogs, may be collected and used by others without restriction.
  • “Cookies” Information: When you access the Service, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer. Siftery may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Persistent cookies can be removed. Please review your web browser “Help” file to learn the best way to modify your cookie settings. Please note that disabling cookies may prevent you from accessing some of the functionality available via the Website. Our ad networks and analytics service providers may also collect information about your use of other websites and online services over time, if those websites and online services also use the same service providers. We currently use Google Analytics to collect and process certain website usage data. To learn more about Google Analytics and how to opt out, please visit www.policies.google.com/privacy/partners.
  • Log Information: When you visit our Website, like many websites’ our servers automatically record information that your browser sends whenever you visit a website (“Log Information”). This Log Information may include information such as your IP address, date and time, browser type and the domain from which you are visiting. For most users accessing the Internet from an Internet service provider (or “ISP”), the IP address will be different every time you log on. We do not use this information to identify you personally. We use it to analyze usage trends, administer the Website and the Service and for the Website’s technical maintenance.

CHILDREN’S PRIVACY

  • Our Website and our Services are not intended for use by persons under 18 years of age. No one under 18 years of age may provide any information to our Website. Specifically, consistent with the Children’s Online Privacy Protection Act of 1998 (“COPAA”) we will never knowingly request personally identifiable information from anyone under the age of 13. Any person who provides information to Siftery represents that they are at least 18 years of age or older. If we learn we have collected or received personally identifiable information from a child under 13, we will immediately delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@siftery.com.

HOW SIFTERY USES THE INFORMATION

  • Siftery uses the information that it collects from its Users to provide safe and optimized access to the Website and the Services. We will use your email address, without further consent, for non-marketing or administrative purposes such as notifying you of major Website updates.
  • Siftery may use all of the information that we collect from our Users to understand usage trends and preferences, to improve the way the Services work and looks, to improve our marketing and promotional efforts, and to create new features and functionality.
  • Siftery may use automatically collected information and cookies information to remember your preferences so you are not required to re-enter some information during your visit or the next time you use the Website or Services.
  • Siftery will not use your email address or other personally identifiable information to send promotional or marketing messages without your consent or except as part of a specific program or feature for which you will have the ability to opt-in.

HOW SIFTERY SHARES THE INFORMATION

  • As a service provider, we do not independently use or disclose Personal Information transferred to us by, or on behalf of, a User for any purpose other than to process that information in order to fulfil our contractual business processing functions, except as may be required or permitted by law. Furthermore, we take all commercially reasonable steps to safeguard the Personal Information we hold against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the Personal Information is held. The precise nature of the safeguards we employ will vary depending on (i) the sensitivity of the Personal Information at issue, (ii) the format in which it is held, and (iii) the manner in which it is stored.
  • Siftery may disclose both personally identifiable and automatically collected information to affiliated companies or other businesses or persons in the field of finance, marketing, server infrastructure, etc., to process such information on our behalf, and to provide, without limitation, website maintenance and security, to offer certain features, to assist us in improving the way the Service works and looks, and to create new features. We require that these parties agree to process such information in full compliance with our Privacy Policy, and we use reasonable efforts to limit their use of such information, and we require these parties to use any other appropriate confidentiality and security measures.
  • Siftery cooperates with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of Siftery or a third party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity. If a user elects to use our referral service for informing a colleague about our site, we ask them for the colleague’s name and email address. Siftery will automatically email the colleague inviting them to visit the site and does not store this information beyond a reasonable term.

DATA SECURITY

  • We use secure server software and firewalls to protect your personally identifiable information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information shall not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software.
  • No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems.
  • If Siftery learns of a security systems breach, then we shall attempt to notify you electronically so that you can take appropriate protective steps. Siftery shall post a notice on the Website if a security breach occurs. In the event of a security breach, we shall send you an email notifying you about the breach. We will use the email you use to register on our Website for all notifications. Depending on where you live, you shall have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at privacy@siftery.com.

OWNERSHIP CHANGE AND BUSINESS TRANSITION

  • In the event Siftery goes through a business transition, such as a merger, acquisition or the sale of all or substantially all of its assets (a “Business Transition”), your membership in Siftery and the Siftery servers containing your personally identifiable information will, in most instances, be part of the assets transferred. In such event, you will be notified via e-mail and/or through a notice on our Website and any other appropriate methods prior to the Business Transition, and Siftery’s custody of your Information will be transferred subject to all the terms and restrictions in this Privacy Policy.
  • Following a Business Transition, Siftery or its successors will continue to use your information in accordance with the Privacy Policy under which the information was collected. If, however, we plan to use your information in a manner different from that stated at the time of collection we will notify you via e-mail and/or through a notice on our Website and any other appropriate methods. You will have a choice as to whether or not we use your Information in this different manner. Whether or not you wish to have your Information used in this different manner, you will at all times retain ownership rights to your information and the ability to delete your Information at any time. Please note, if you have deleted or deactivated your account on our Website or are an opt-out User, then you will not be contacted, nor will your information be used in this different manner.

OPT-OUT AND DEACTIVATION OF ACCOUNT

  • When you deactivate your Account (as defined in the Terms of Service) or opt-out of receiving our Services by sending us an email at privacy@siftery.com, we will delete all your information from our records without any undue delay.

LOG FILES AND BACKUP

  • Like most Internet services, we use log files, both on the client and server side. The data held in log files includes your IP address, browser type, e-mail application, Internet service provider (“ISP”), referring/exit Web pages, computer platform type, date/time stamp, and user activity. Siftery uses server log data to analyze trends, administer the Services and the Website, and improve service levels. IP addresses are not tied to any personally identifiable information.
  • The Services provided by Siftery have associated log and temporary files that are stored on your local hard drive and on Siftery’s servers. These files store your Account Information (defined in the Terms of Service), your permissions, preference settings, system notifications as well as other data necessary to operate and provide you with the Services
  • Your Information may also exist temporarily within regularly performed server backups.

PHISHING

  • We do not and will not, at any time, request your credit card information, your Siftery user name, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
  • Identity theft and the practice currently known as “phishing” are of great concern to Siftery. Safeguarding information to help protect you from identity theft is our priority.

YOUR CHOICES

  • You may, of course, decline to share your personally-identifiable information with Siftery, in which case Siftery will not be able to provide to you some or all of the features and functionalities of the Website and the Services. Users also have the flexibility to review, update, correct or delete their personally identifiable information shared on their Siftery profile. If Users completely delete any such information, their use of the Services may be limited or terminated. If you would like us to delete your records in our system, you can do so via the interface features provided on the Website or contact us at privacy@siftery.com.com and we will accommodate your request without undue delay.

DATA RETENTION

  • We reserve the right to retain your personally identifiable information or other data collected from you as a result of your use of the Website and the Services in order to prevent fraud and misuse of the Website and the Services.

SECURITY AND INTERNATIONAL TRANSFERS

  • Siftery is very concerned with safeguarding your information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. Your information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Siftery transfers your information to the United States and maintains and processes it there. You hereby consent to such transfer. IF YOU DO NOT WISH TO ALLOW SIFTERY THE ABILITY TO TRANSFER YOUR PERSONALLY IDENTIFIABLE INFORMATION TO THE UNITED STATES, PLEASE DISCONTINUE USING OUR WEBSITE AND SERVICES AND DEACTIVATE YOUR ACCOUNT.

LINKS

  • The Website and the Services may contain links to other third-party websites. Please be aware that Siftery is not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave the Website or otherwise link to other sites, to read the privacy policies of each and every site that collects personally identifiable information. Siftery’s Privacy Policy applies solely to information collected by Siftery when Users use and access the Siftery Website and Services.

GOVERNMENT AUTHORITY

  • You should be aware that, as with all legal contracts, our Terms of Service and this Privacy Policy could be amended, terminated or modified without the consent of you and/or Siftery by judicial proceeding, court order, in connection with bankruptcy or other insolvency proceedings, or pursuant to other government action. When reasonable and lawful, we will notify you if this occurs.

TRAINING AND MANAGEMENT OF SIFTERY ASSOCIATES

  • We educate our associates about our information security policies and practices and use reasonable efforts to help ensure that our associates comply with these policies and practices. These efforts include: conducting appropriate background checks of all newly-hired associates; including information on Siftery’s policies (including the privacy policies) in our associate orientation process; requiring associates to execute appropriate non-disclosure agreements; including information on our policies and practices on the Siftery Website; disseminating information on our policies and procedures to associates at appropriate intervals; limiting access of User personally identifiable information to our associates with a business need for seeing it; promptly ending associate access to systems and facilities upon termination of associates relationship with Siftery; monitoring associates for compliance with policies; and imposing appropriate and stringent disciplinary measures for breaches of policies and procedures.

HOW WE ENSURE SECURITY OF OUR FACILITIES AND OFFICES

  • We use third-party server hosting partners’ highly secure infrastructure to host all our applications. We may also host your Personal Information on our servers. Please contact us at privacy@siftery.com for further information about security at our third-party server hosting partner or our servers.

HOW WE ENSURE THE SECURITY OF OUR INFORMATION SYSTEMS

  • Information systems include network and software design, as well as information processing, storage, transmission, retrieval and disposal. We employ policies and practices to protect personally identifiable information throughout its life cycle – from data entry to data disposal. These policies and practices include, among other things:

    • Requiring use of virus protection software on all computer systems attached to Siftery client server network;
    • Limiting all access to Siftery resources and networks to approved configurations and utilizing appropriate identification and authentication methods;
    • Utilizing firewalls (which are configured and maintained in accordance with industry-standard procedures and specifications);
    • Requiring appropriate disposal of all documents and electronic media containing Personal Information;
    • Employing appropriate intrusion detection, monitoring, and logging capabilities to enable detecting and responding to potential security breaches;
    • Maintaining appropriate incident handling procedures for responding to any breaches;
    • Regularly obtaining and installing patches to address software vulnerabilities;
    • Developing client applications utilizing appropriate security methods including multiple-factor authentication, strong passwords, session time-outs, and access controls;
    • Encrypting of data in transit, rest and backups;
    • Maintaining adequate disaster recovery and business continuity plans for all core functions.

ADDITIONAL SAFEGUARDS TO PROTECT INFORMATION

  • Due to the constantly changing nature of technologies and security concerns, we conduct appropriate, periodic reviews of our security policies and practices. Additionally, periodic assessments are conducted as appropriate. All allegations of system or data misuse (by associates, contractors or any third parties) are thoroughly investigated by Siftery in accordance with our policies and reported to law enforcement authorities where appropriate.

RETAINING YOUR INFORMATION

  • We may keep a record of User’s Personal Information, correspondence or comments in a file specific to the User, to which access by our associates and by any third parties with whom we contract will be strictly limited on a business need-to-know basis. We will retain User’s Personal Information for as long as necessary to fulfil the purposes for which it was transferred to us, or as required or permitted by law. We have established minimum and maximum retention periods, as well as appropriate procedures for the destruction and disposal of Personal Information.

UPDATING YOUR PERSONAL INFORMATION

  • As a service provider of business processing functions, we rely on our Users to provide us with updated Personal Information on an ongoing basis, as necessary in relation to our provision of the services. Upon receipt of updated personal information, we will amend the User’s personal information that we hold where such amendment is reasonably necessary to enable us to continue providing the services to the Client in accordance with our contractual obligations as a service provider. This updating of personal information is rarely performed.

YOUR CALIFORNIA PRIVACY RIGHTS AND DISCLOSURES

California Shine the Light Law. We do not disclose your Personal Information to third parties for such parties’ direct marketing purpose. However, if you are a California resident and if you believe that we disclose your personally identifiable information to third parties for such third parties’ direct marketing purposes, California’s Shine the Light Law (CA Civil Code Section 1798.83) allows you to request certain information from us about such disclosures. To make a request under the Shine the Light Law, please contact us at legal@siftery.com. Please note that under California law, businesses are not required to respond to such requests more than once during any calendar year.

CHANGES AND UPDATES TO THIS PRIVACY POLICY

  • We may occasionally update this Privacy Policy. When we do, we will also revise the “Last Updated” on our Website. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal information that you have provided to us, we will use commercially reasonable efforts to obtain your consent before implementing the change. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the information we collect. Your continued use of the Service constitutes your agreement to this Privacy Policy and any updates thereof.

CONTACTING US

If you have any questions, comments, or concerns about this Privacy Policy, please contact us at:
Email: privacy@siftery.com
Address: Siftery Inc, 855 Folsom St, Suite 108, San Francisco CA 94107