Privacy Policy

Privacy Policy

Updated and effective as of January 1, 2020.

Last Updated: February 7, 2020

This privacy policy (the “Privacy Policy”) only applies to the information that Eze Castle Software LLC (collectively, with its affiliates ("Eze") gathers through its website www.ezesoft.com and any other website controlled by Eze that posts this Privacy Policy ("Web Site"). This Privacy Policy does not apply to our specific service offerings that we offer to clients or to information collected offline, unless specifically noted.  The following discloses our information-gathering and dissemination practices for our Web Site. By using our Web Site, you consent to the collection and use of this information by Eze. Our Web Site is general-audience in nature and are not intended for individuals younger than the age of 18.

Summary

WE FULLY DESCRIBE OUR PRIVACY PRACTICES BELOW IN THIS PRIVACY POLICY.   THIS SUMMARY PROVIDES AN OVERVIEW OF SOME IMPORTANT INFORMATION REGARDING OUR USE AND SHARING OF INFORMATION AND THIRD PARTIES WHO MAY SERVE ADVERTISEMENTS AND WHO OTHERWISE MAY SET COOKIES OR SIMILAR TRACKING TECHNOLOGIES WHEN YOU INTERACT WITH THE WEB SITE. PLEASE REVIEW OUR FULL PRIVACY POLICY BEFORE USING OUR WEB SITE.

We may collect Personal Information from you, which we primarily use in connection with your relationship with Eze, your use of the Web Site, and for sending you information from us or on behalf of certain third parties. Please review the “Information We Collect and How We Use It” section of this Privacy Policy for a full description of the information we collect, including Personal Information, and how we use that information. Note that we do not share your Personal Information with third parties for marketing purposes without your consent; however, we may share your Personal Information under certain limited circumstances.  For more details, please review the section below entitled “How and When We Disclose Information to Third Parties.”

In addition, Eze works with network advertisers, ad agencies, analytics providers and other vendors to provide us with information regarding traffic on the Web Site, including the pages viewed and the actions users take when visiting the Web Site; to serve third-party advertisements on the Web Site and to serve our advertisements elsewhere online; and to provide us with information regarding the use of the Web Site and the effectiveness of our advertisements. These third parties may set and access their own tracking devices (including cookies and web beacons) and they may otherwise collect or have access to information about you and your visits to this or other websites, and may use that information to serve you targeted ads on this and other websites.  Please review “Third Party Analytics Providers, Ad Servers and Similar Third Parties” for additional information. Some of these companies are members of the Network Advertising Initiative ("NAI”) or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. You may want to visit www.networkadvertising.org/managing/opt_out.asp for NAI and http://www.aboutads.info/choices/ for DAA, which provide information regarding targeted advertising and offer an "opt out" for participating companies. 

Information We Collect and How We Use It

We, and our service providers, collect a variety of information from users as they visit the Web Site. For example, you may provide us with information, including personal information (information that is linked to a specific, identifiable individual, such as email address, and first and last names) (“Personal Information”), demographic information (your age, gender or similar information), and business information (including your employer, and business contact information). If we associate non-personal information with Personal Information we will treat the combined information as Personal Information. We mainly use Personal Information to communicate with you, such as through our email newsletters, to contact you about your request for a demo, to reply to a question, or to respond to your employment application. You may choose to remove yourself from our newsletter and promotional email mailing list (i.e., opt out), by following the link provided in the email received.

In addition, Eze collects non-personally identifiable usage data (“Usage Data”) via cookies, web beacons and similar technologies as further described in the Tracking Technologies section below. Usage Data includes information about our visitors and how they use our Web Site, including browser type, the website you were visiting before you visited the Web Site, time of day and your IP address, your mobile device advertising identifier and similar device identifiers. We use Usage Data for a variety of purposes, including to improve our Web Site and services.

We may also receive information about you from third parties and we may supplement the information we collect with outside records.  We may combine the information we receive from those other sources with information we collect through the Site. In those cases, we will apply this Privacy Policy to the combined information.  

We and our service providers will use information collected through the Eze Web Site to provide features and services, to contact you with information, to process your job application or other request, to serve you advertisements on the Web Site and elsewhere online for internal business purposes, for customer service purposes and as otherwise described in this Privacy Policy. 

Tracking Technologies

We, and our third-party service providers, may use cookies, web beacons and other tracking technologies to gather Usage Data about visitors and how they use our Web Site. We use this information to improve our Web Site, to target advertisements to users, and for other business purposes. The tracking technologies we use include the following:

Cookies and Local Storage.  “Cookies” and local storage are pieces of information (data files) transferred to a browser when the user visits a site. These technologies are able to store a unique identifier for a device to allow an online service provider to recognize the device whenever the device is used to visit the site. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences, tracking your visits to our web pages, and facilitating your transactions. We use both session and persistent cookies (which remains on your computer after the browser has been closed). You may set up your computer to reject cookies by the privacy settings for your web browser although, in that case, you may not be able to use some of the features on our Web Site. You can find more information about cookies and how they work at www.allaboutcookies.org.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “pixel tags,” “1×1 GIFs,” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, to count visitors to the Web Site, to monitor how users navigate the Web Site, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Web Site, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Web Site, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

Social Network, Platform Integration, and Third Party Links

The Web Site may contain integration with social networks and other platforms. For example, the Web Site may contain buttons that direct users to our social networking pages (such as Facebook or Twitter), enabling you to “like” or “share” the Web Site's content to other online services, or display tweets or other content from third party platforms on the Web Site, in accordance with the terms of that third party platform. If you choose to “like” or “share” content or to otherwise post information via the Web Site to a third-party website or other online service, that information may be publicly displayed and the third-party website may have access to information about you and your use of our Web Site.

In addition, the Web Site may have links to third party websites. If you click on social networking buttons or third party links, you will be taken to those third parties websites, and your use of those third parties’ websites and platforms are subject to their privacy policies and practices. We are not responsible for the privacy or business practices of any third party.

How and When We Disclose Information to Third Parties

Eze may share non-Personal Information, such as Usage Data, Personal Information that has been de-identified (typically using a hash function) and aggregated user statistics, with third parties in our discretion. We do not share Personal Information with third parties for those third parties’ own direct marketing purposes without your express consent, unless you have accessed information on the Web Site about such third party, its products or services, in which case Eze may share your Personal Information with that third party.  We may share the information we have collected about you (including Personal Information) with third parties as disclosed at the time you provide your information, with your consent, as described in this Privacy Policy, and under the following circumstances:

• with our vendors and third-party service providers to perform certain services on behalf of the Web Site, such as hosting the Web Site or Web Site features, processing employment applications, sending email or other communications, and providing marketing assistance and data analysis;
• to comply with legal process or a subpoena, or at the request of a governmental entity conducting an investigation, and to protect and defend the legal rights or property of Eze, our Web Site or its users, or any other party;
• with its affiliates, primarily for business and operational purposes; and
• in connection with a business transition (such as a merger, acquisition by another company, bankruptcy, or sale of all or a portion of assets), including during the course of any due diligence process; during such business transition your Personal Information will likely be among the assets transferred; by providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.

In addition, if you apply for a job through the Web Site, Eze may ask you to provide self-identifying information (such as veteran status, gender and ethnicity) in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”) and other federal, state and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, Eze or its service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints.

Third Party Analytics Providers, Ad Servers and Similar Third Parties

We may work with network advertisers, ad agencies, analytics service providers, and other vendors to provide us with information regarding traffic on our Web Site (including pages viewed and the actions taken when visiting our Web Site), to serve, or assist us in serving, our advertisements on other websites, within mobile apps, and elsewhere online, and to provide us with information regarding the use of our Web Site and the effectiveness of our advertisements. For example, if you view or click on an advertisement for Eze or one of our products, our service provider(s) may be able to tell us the advertisement that you clicked on and where you were viewing the advertisement.

These service providers may set and access their own tracking technologies on your device (including cookies and web beacons and may otherwise collect or have access to information about you. Some of these parties may collect Personal Information over time when you visit the Web Site or other online websites and services. We may share Usage Data or de-identified data about visitors with third-party advertising companies, analytics providers and other vendors for analytics and advertising purposes.

We use a variety of service providers to perform advertising services. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp,  which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. You can also learn more and make choices about interest-based advertisements from participating third parties, by visiting the Canadian DAA online choice page at http://youradchoices.ca/choices/, the  European DAA online choice page at http://youronlinechoices.eu and the Australian DAA online choice page at http://www.youronlinechoices.com.au/opt-out/. 

Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online.

How We Respond to “Do Not Track” Signals

Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Eze does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Updating Your Information

If you would like to update, delete, or revise any Personal Information you submitted to us through the Web Site please send your request to privacy@ezesoft.com.

Protection of Personal Information by Eze

We employ commercially reasonable security methods and technologies to help secure your Personal Information. However, no system can be guaranteed 100% secure. We therefore cannot ensure or warrant the security of any information that you transmit to us, or that we transmit to you, or guarantee that it will be free from unauthorized access by third parties. You use the Web Site and provide us with information at your own initiative and risk.

Consent to Transfer

We operate the Web Site from the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States and other jurisdictions. By visiting the Web Site, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

Changes to this Privacy Policy

We may modify this Privacy Policy from time to time in our sole discretion and any changes will be effective upon posting of the revised Privacy Policy unless otherwise specified. If there are material changes to the way we treat Personal Information, we will notify you by posting the updated Privacy Policy on our Web Site. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Your continued use of our Web Site following the updated Privacy Policy will mean you consent to those changes.

Contact Us

If you have questions or comments about our use of your information or about this Privacy Policy, please contact us by email at privacy@ezesoft.com or by mail at Eze Castle Software LLC, 12 Farnsworth Street, 6th Floor, Boston, MA 02210. EU residents should see additional information below.

RESIDENTS OF THE EUROPEAN UNION (EU) AND EUROPEAN ECONOMIC AREA (EEA)

This section of the Privacy Policy applies only if you use our Web Site and are a resident of a country that is a Member State of the European Union or European Economic Area (collectively, “EU”), and it supplements the information in the Privacy Policy.

For purposes of the EU General Data Protection Regulation (“GDPR”), Eze Castle Software LLC (“Eze”) is the data controller for processing of information defined as personal data under applicable data protection law (“Personal Data”).

LEGAL BASIS FOR DATA PROCESSING

We process Personal Data for the purposes set out in our Privacy Policy. Our legal basis to process Personal Data includes processing that is: necessary for the performance of a contract between us (for example, to provide you with services you request and to identify and authenticate you so you may use the Web Site); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you and to improve the Web Site and our services); and based on consent by our customers (for example, to communicate with you about our products and services and provide you with marketing information), which may subsequently be withdrawn at any time by contacting us (using the contact instructions below). Where we ask you for personal data, we will tell you if it is optional.  Otherwise, we are asking because it is necessary in order for us to provide the requested information or complete the requested transaction.

EU DATA SUBJECT RIGHTS

The GDPR provides certain rights for EU data subjects. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your Personal Data, and the right to access your Personal Data and update or correct it.  In some cases, you can also ask us to erase it, restrict or stop processing, or provide data in a “portable” form, if feasible.  You may withdraw consent (“opt-out”) if you have previously consented to any particular use of your information, such as receiving emails or text messages.  Requests should be submitted by contacting us, using the contact instructions below). We will make commercially reasonable efforts to provide you reasonable access to your personal information within 30 days of your access request to the contact address below.  If we cannot honor your request within 30 days, we will inform you when we will be able to provide such access. If for some reason access is denied, we will provide an explanation as to why access is denied.

If you have any privacy-related concern, please contact us (using the information set forth below).  If you have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Data Protection Authority and lodge a complaint.

RETENTION

We retain your Personal Data while you have an account with us and while you continue to visit our Web Site. We will retain your Personal Data for as long as it is reasonably necessary for the purposes set out in the Privacy Policy and the purposes for which it was collected, and additionally, for as long as necessary to comply with legal and regulatory requirements, professional accounting and audit standards, legal or insurance claims, or regulatory proceedings; to protect against and assist in the prosecution of fraud or crime; to comply with our contractual obligations and our business policies; as allowed by law to protect our legitimate interests and to protect our property and enforce our terms for use for the Web Site or our services.

THIRD PARTY ONLINE ADVERTISING

As discussed in our Privacy Policy, we work with online analytics and advertising companies, and those companies may set cookies or other tracking technologies in connection with providing advertising related services to us. The European Digital Advertising Alliance ("EDAA") has developed a guide to online behavioural advertising and has developed an opt out page to manage online behavioural advertising preferences with participating EDAA member companies available at www.YourOnlineChoices.com.

CONSENT TO TRANSFER

As noted in our Privacy Policy, we operate the Web Site in the United States and other jurisdictions, and by visiting the Web Site or providing us with any Personal Data, you consent to the collection, transfer and processing of your data in the United States and other jurisdictions, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

CONTACT US

Our representative office in the European office is:  Eze Software EMEA Limited, Old Change House, 3rd Floor, 128 Queen Victoria Street, London, EC4V 4BJ, United Kingdom. 

You can also contact us via email at privacy@ezesoft.com.  For all EU Data Subject Rights requests sent by email, you must put the statement "Your EU Data Subject Rights" in the subject field of your request and include in the request the name of the Services with respect to which you are requesting the information, as well as your contact information.

CALIFORNIA CONSUMER PRIVACY ACT (CCPA) NOTICE

This California Consumer Privacy Act Notice, in conjunction with the preceding portions of this privacy policy, provides information for certain California residents in connection with the California Consumer Privacy Act of 2018 (“CCPA”).  Under the CCPA, and for purposes of this California Consumer Privacy Act Notice portion of this Privacy Policy and Notice, “Personal Information” generally means information that identifies, relates to, or describes a California resident or household and includes the categories listed below.  Below are details about the categories of Personal Information of California residents that we have collected or disclosed during the last 12 months.

Information Collected.  We collect the following categories of Personal Information: 

A. Identifiers, such as (but not limited to) name and online identifiers;

B. Personal information, as defined in the California customer records law, such as (but not limited to) contact information and financial information;

C. Characteristics of protected classifications under California or federal law, such as (but not limited to) age, gender, and marital status; 

D. Commercial information, such as transaction information;

E. Internet or network activity information, such as browsing history and interactions with our websites;

F. Geolocation data, such as device location;

G. Audio, electronic, visual and similar information, such as call and video recordings;

H. Professional or employment-related information, such as work history, prior employer and reference contact information; and

I. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Depending on a California consumer’s particular interactions and relationship with us, we may not collect each of the above categories of Personal Information about each consumer.

Sources of Personal Information.  We collect this Personal Information directly from California residents themselves, as well as from other sources, such as public databases, your employer and its employees, our affiliates, third-party sources of demographic information, and social media platforms.

Purposes.  We use this Personal Information to operate, manage, and maintain our business, to provide our products and services, to communicate with our customers, prospective customers, vendors, employees and other associated entities and persons, and to otherwise accomplish our business purposes and objectives.  Our business purposes and objectives include, for example, developing, improving, supporting, servicing and maintaining our products, services, customer relationships and employee relationships; personalizing, advertising, and marketing our products and services; conducting research, analytics, and data analysis; maintaining our facilities and infrastructure; undertaking quality and safety assurance measures; conducting risk and security controls and monitoring; detecting and preventing fraud; performing identity verification; performing accounting, audit, and other internal functions, such as internal investigations; complying with law, legal process, and internal policies (including responding to requests from California residents under the CCPA); maintaining records; and exercising and defending legal claims.

Disclosures of Personal Information.  We may disclose the categories of Personal Information listed above to our affiliates and to third parties, such as our service providers, for our operational business purposes.

Depending on a California consumer’s particular interactions and relationship with us, we may not have disclosed each of the above categories of Personal Information about each consumer.

Sales of Personal Information.  We have not “sold” Personal Information for purposes of the CCPA. 

For purposes of this CCPA Notice, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

If you are a California resident, you have the following rights:

(1) Right to Know.  You have the right to request that we disclose to you the following information covering the 12 months preceding your request:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The specific pieces of Personal Information we collected about you;
• The business or commercial purpose for collecting Personal Information about you; and
• The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information.

(2) Right to Request Deletion.  You have the right to request that we delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please click here or call us at 1-844-439-3763.  We will respond to your request consistent with applicable law. 

(3) Right to Be Free from Discrimination.  You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.