and/or any related end clients, tools, applications, data, software, Application Program Interfaces (APIs) or other services (collectively, the “Service” or “Services”) related thereto, how it will be used, and how you can control the collection and use thereof.
Greetly also recognizes that the European Economic Area (EEA) and United Kingdom (UK) have established strict protections regarding the handling of personal data, including requirements to provide adequate protection for such personal data transferred outside of the EEA and the UK. To provide adequate protection for personal data received by Greetly in the U.S. from the EEA and the UK, Greetly has elected to self-certify to the EU-U.S. Privacy Shield Framework administered by the U.S. Department of Commerce (“Privacy Shield”). Greetly adheres to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.
Information That May Be Collected by Us
Information that you give us. You may provide us information about yourself when you register with or use Greetly’s Services.
This may include your name, postal address, email address, phone number(s), username, password, photographs that you upload, your account information related to web tools (e.g. automation tools, messaging apps) that you utilize, time zone, demographic information, information related to your occupation (e.g. company, title, office location), and information related to visitors to your offices (e.g. name of visitor and arrival and departure times). If you correspond with us via email, chat, Website form submission, in writing, or by telephone, we may retain the content of those communications and our responses, as well as your email address, mailing address, and/or telephone number. In addition, you may provide information about yourself by filling out forms or by completing surveys created by us.
Information automatically collected. We (directly or through our third-party service providers) may automatically log information about you and your computer. Log file information is automatically reported by your browser each time you access our Services. When you register with, view, or use our Services, our servers automatically record certain information. These server logs may include information such as your web request, IP address, operating system type, browser type, browser language, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, how long you spent on a page, access times, and other similar types of information.
Information we get from others. We may get information about you from third parties and/or from other sources, for example by collecting data that is publicly available (e.g. information you submit in a public form).
Clear gifs information. When you use the Website, we may employ clear gifs which are used to track the online usage patterns of our users anonymously. No personally identifiable information is collected using these clear gifs. In addition, we may also use clear gifs in emails sent to our users to track which emails are opened by recipients.
Information of minors. We do not intend to solicit or collect any personally identifiable information from children under the age of 13 years old. If we learn that a child under the age of 13 has provided personally identifiable information to us, we will promptly remove such information from our file. If you believe that a child under the age of 13 has disclosed personally identifiable information to Greetly, please report this to us immediately by emailing us at firstname.lastname@example.org. We do not require a child under the age of 18 to disclose more information than is reasonably necessary to participate in an activity as a condition of participation. If a child under the age of 18 has provided personally identifiable information, a parent can review the child’s personal information, ask to have it deleted and refuse to allow any further collection or use of the child’s information by emailing us at email@example.com. Parental consent is required for the collection, use and disclosure of the information collected from children under the age of 18. A parent can provide consent or revoke it at any time by contacting us in accordance with the methods identified below under the heading “Contact Us”. Parents have the option to agree to the collection and use of the child’s information without consenting to the disclosure of the information to third parties.
How We Use Your Information
We use your personal information as follows:
- We use your personal information to operate, maintain and improve our sites, products, and services. In particular, this includes sending push notifications to personnel within your organization.
- We use your personal information to respond to comments and questions and provide customer service.
- We use your personal information to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
- We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
- We use your personal information to process and deliver contest entries and rewards.
- We use your personal information to link or combine user information with other personal information.
- We use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
How We Share Your Information
Personally identifiable information. We may share personal information in a variety of ways, including as follows:
- We may share your personally identifiable information with third parties for the purpose of providing the Services to you or for internal administrative purposes. For example, we may share your personal information with third-party agents or service providers who perform functions on our behalf in connection with our providing the Services. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process personal information in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of personal information that we transfer to them.
- We may share personal information with your consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
- We may share personal information for legal, protection, and safety purposes. For example, we may disclose identifiable personal information to third parties when required to do so by law or subpoena or if we believe that such action is necessary (a) to conform to applicable law, to comply with legal process served on us or our affiliates (including, without limitation, any investigation by a regulatory agency or other valid requests by public authorities, including to meet national security or law enforcement requirements), or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to investigate and monitor compliance with, and to protect or enforce our rights, including under the Terms of Service or our other agreements and policies, to take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our site; or (c) to exercise or protect the rights, property, or personal safety of us, our employees and agents, our users and customers, or others, including without limitation, to credit reporting or collection agencies in connection with efforts to collect any amounts owed by you to us. The aforementioned may include, but is not limited to, exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- We may share information with those who need it to do work for us.
- We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
- We may store personal information in locations outside of our direct control — for instance, on servers or databases located with hosting providers.
Non-personally identifiable information. We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and Uniform Resource Locators (URLs), platform types, number of clicks, etc.) with third parties who wish to understand the usage patterns on our Services.
- We may disclose certain information about you and/or your use of our Services to third parties without identifying your personally identifiable information for any lawful purpose, including, but not limited to, analyzing how our Services are used, diagnosing technical problems, maintaining security, and personalizing advertisements and promotions. We may de-identify personally identifiable information and share it in a de-identified or aggregated form with third parties, advertisers and/or business partners for any lawful purpose.
How We Protect Your Information
We use commercially reasonable safeguards to preserve the integrity and security of your personal information. Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. We will use commercially reasonable efforts to restrict employee access to personally identifiable user information to those who need to know it in order to provide the Services to you. We cannot, however, ensure, warrant or guarantee the security of any information that you transmit to us, and you do so at your own risk. We make no guarantee that such information will not be accessed, disclosed, altered, or destroyed notwithstanding our safeguards.
To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, you are responsible for maintaining the confidentiality of your account and password and for restricting access to your computer. You hereby agree to accept responsibility for all activities that occur under your account or password.
Compromise of Personal Information
Your Access to and Choices About Your Information
You may decline to submit certain information to us, in which case we may not be able to provide certain Services to you. You may update your account information and email preferences at any time by signing into your account. You are solely responsible for helping us to maintain the accuracy and completeness of your personal and other information. We urge you to review your information regularly to ensure that it is correct and complete. If you believe that any of your information is incorrect please email us at firstname.lastname@example.org.
You may opt out of any future contact from us at any time. You can do the following at any time by emailing us at email@example.com. You can also choose to opt-out of our sharing of your personal information with third parties, except where the disclosure has already been made to a third party in accordance with this Policy or where the disclosure is made to a third party that is acting as a service provider for Greetly. We will also not use or disclose your personal information for a purpose that is materially different than the purpose it was collected for without notifying you and requesting your consent. If you choose not to consent to such use or disclosure, you may choose to decline or opt-out of it at that time.
Please note that any opt-out requests may take a reasonable period of time for us to process.
As noted above, you can access and change your personal information in your account. You may also have the right to access the personal information that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided above. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Links to Other Websites
Applicable Law and Jurisdiction; Dispute Resolution
In compliance with the Privacy Shield Principles, Greetly commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Greetly at:
firstname.lastname@example.org with the subject line “privacy”.
Greetly has further committed to refer unresolved Privacy Shield complaints to the Denver, Colorado, United States office of the American Arbitration Association (http://go.adr.org/privacyshield.html), an alternative dispute resolution provider. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit the American Arbitration Association for more information or to file a complaint. European Union individuals have the right to invoke binding arbitration. The services of the American Arbitration Association are provided at no cost to you.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. Greetly has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.
Greetly welcomes your feedback. Please contact us by email at email@example.com or by snail mail at Greetly, Inc., 1805 S. Bellaire St #501, Denver, CO 80222, United States.
Effective as of May 20, 2015; updated March 10, 2020.