Privacy Policy

Last Updated: August 5, 2021

This Privacy Policy outlines how Emmre LLC. ("we" or "us") collects and uses our user's ("you" or "your") personal information, which we gather from our websites, services, and desktop and mobile applications (collectively referred to as "Emmre"). We strive to ensure that any personal data we collect about you will be held and processed strictly in accordance with applicable data protection legislation, as set out in this notice.

This Privacy Policy also describes the choices you have regarding personal data we've collected about you. "Personal information" or "personal data" is any information that can be used to contact or identify a single individual.

Applicability Of This Privacy Policy

This Privacy Policy applies to Emmre's online productivity tools and platform, including the associated Emmre mobile and desktop applications (collectively, the "Services"), Emmre.com and other Emmre websites (collectively, the "Websites") and other interactions (e.g., customer service inquiries, sales calls, etc.) you may have with Emmre. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Emmre's business.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Emmre platform ("Third Party Services"), or any other third party products, services or businesses.

Data processed by Emmre can be classified in two ways:

Data that has been collected by us for our own purposes; and data collected by our users and used for their purposes. For example, your employer may collect data about you and use this data to communicate with you.

This policy specifically covers data that is collected by us. We are not responsible for, nor do we have control over, the use of data that is collected by users of Emmre.

By using Emmre, you agree to the collection and use of your personal data in accordance with this policy. Terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

How We Collect Personal Information

We collect several different types of personal data, which we use as described in this Privacy Policy (See "How We Use Personal Information," below). For instance, we collect data:

During signup

When you sign up for Emmre, we ask you to provide us with the following personal data:

- The name of the Organization (i.e., Company) you are affiliated with
- Your email address
- Your first name and last name
- Cookies and Usage Data (discussed below)

We use this information for creating and administering your account. We also may use this information to contact you and send you newsletters, marketing or promotional materials, or other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by clicking on the unsubscribe link in the emails, or by contacting our support team at support@emmre.com.

Automatically while you are using Emmre

We also automatically collect information on how Emmre is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages that you use/visit, the time and date of your visit or use, the time spent on those pages or features of Emmre, unique device identifiers and other diagnostic data. We use this data to analyze Emmre's performance and make our services more effective.

Through the use of Cookies

We use cookies and similar tracking technologies to track the activity on Emmre and we retain this information to provide and improve Emmre.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze Emmre.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of Emmre.

Examples of Cookies we use:

- Essential Cookies: These cookies are essential to provide you with Emmre. For example, they allow you to log in.
- Functionality Cookies: These cookies allow us to remember choices you make, or to provide certain features, such as which filters you use or sorting preferences.
- Analytics and Performance Cookies: These cookies are used to collect information about traffic to our Services and how users use our Services.
- Google Analytics. We use Google Analytics. We use the information we get from Google Analytics only to improve this site. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google's Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.
- Advertising and Targeting Cookies: These cookies are used to deliver advertisements more relevant to you and your interests. They remember that you have visited a website and this information is shared with other organizations such as advertisers.
- Google Ads. We also use Google Ads to deliver tailored advertising on our Sites and other websites that you may visit. Where offered by Google, we have enabled restricted data processing for users in California. This means that certain features will be unavailable to us, such as adding users to remarketing lists, adding users to similar audience remarketing seed lists, and related functionality.

All users may learn more about how to control advertising cookies by visiting the Network Advertising Initiative's Consumer Opt-Out link, the DAA's Consumer Opt-Out link for browsers, or the DAA's opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.

When you choose to provide us with information

You may choose to provide us with personal information while interacting with us in various ways. For example, when you submit a request for help. This information is only used for the purposes for which it was provided.

How We Use Personal Information

We use collected information for the following general purposes:

- To provide and maintain Emmre
- To notify you about changes to Emmre
- To allow you to participate in features of Emmre
- To provide customer support
- To gather analysis or valuable information so that we can improve Emmre
- To detect, prevent and address technical issues
- For billing purposes
- To identify and authenticate users
- To prevent fraud and spam
- To provide you with products or services you have requested, such as newsletters
- To communicate special offers and information that we think may be of interest to you, such as an offer for a free trial to a new feature of Emmre

**We do not sell your personal data to others.**

Service Providers

We share information with third parties who provide services on our behalf to help with our business activities and to provide Emmre. These companies are authorized to use your personal information only for the sole purpose of providing services to us. These services include:

- Fulfilling orders
- Processing payments
- Providing customer service
- Sending marketing communications
- Fulfilling subscription services
- Conducting product research and analysis
- Providing and maintaining a cloud computing environment
- Fixing bugs

We use third-parties to monitor and analyze the use of Emmre. However, these services are configured in such a way that the third parties are not allowed to use your activity for their own purposes, such as personalizing ads on other websites.

Retention of Data
We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. We will also retain Usage Data for internal analysis purposes.

Disclosure of Data

Business Transaction

If we are involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement
Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

We may disclose your personal data in the good faith belief that such action is necessary to:

- To comply with a legal obligation
- To protect and defend the rights or property of our company
- To prevent or investigate possible wrongdoing in connection with Emmre
- To protect the personal safety of users of Emmre or the public
- To protect against legal liability

With Consent

Emmre may share Other Information with third parties when we have consent to do so.

Security

Emmre takes security of data very seriously. Emmre works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, Emmre cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don't control or endorse what is on third-party sites.

If a breach of data occurs within Emmre, we will inform you via a notification posted within Emmre and via email at your last listed email address within 30 business days of discovering the breach. By using Emmre, you acknowledge and agree that we may send you electronic notifications via email instead of notifications by mail. If you would still like to receive notifications by mail, you can let us know by contacting us at support@emmre.com.

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the "controller" and "processor" of information. In general, Customer is the controller of Customer Data. In general, Emmre is the processor of Customer Data and the controller of Other Information. Different Emmre entities provide the Services in different parts of the world. Emmre LLC, a US company based in Colorado Springs, Colorado is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Workspaces established for Customers in the US and Canada.

Your Rights

In General

Upon request, we will provide you with information about your personal data (such as the categories of personal information that we have collected about you, the specific pieces of personal data that we have collected about you, and the categories of sources from which your personal information is collected). You may request access, correct, request the deletion of, or object to our use of your personal information by contacting us at support@emmre.com. If you email us, please include "Personal Data Inquiry" as the subject line. Please note that we may ask you to verify your identity before responding to such requests. We will respond to your request within a reasonable timeframe and as set forth by the applicable laws.

We have listed the privacy rights for several jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws.

In certain circumstances, we may be required by law to keep your personal information, or we may need to retain your personal information in order to continue providing Emmre. Please note that we can only provide you with information about your personal data that we collect and use. We do not have control over, or information about, your personal data that other users collect or use.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal data. If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us at support@emmre.com. If you email us, please include "Personal Data Inquiry" as the subject line.

In certain circumstances, you have the following data protection rights:

- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your personal data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

If we don't resolve your concern in a reasonable time frame, you have the right to lodge a complaint with your local supervisory authorities.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Your Data Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California consumer, you have the following rights under the CCPA:

- The right to know what personal information is being collected about you.
- The right to know whether your personal information is sold or disclosed and to whom.
- The right to say no to the sale of personal information.
- The right to access your personal information.
- The right, in certain circumstances, to delete the information you have provided to us.
- The right to equal service and price, even if you exercise your privacy rights.

Request for Information and Deletion (CCPA). California consumers have the right to request, up to twice in a 12-month period, that a business that collects personal information about the consumer disclose to the consumer the information listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information.

1. The categories of personal information it has collected about that consumer.
2.  The categories of sources from which the personal information is collected.
3.  The business or commercial purpose for collecting or selling personal information.
4.  The categories of third parties with whom the business shares personal information.
5. The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
6.  The categories of personal information that the business disclosed about the consumer for a business purpose.
7.  The specific pieces of personal information it has collected about that consumer.

To make such a request, please contact us at support@emmre.com. If you email us, please include "Personal Data Inquiry" as the subject line.

Do Not Sell My Personal Information (CCPA).

California consumers have the right to opt out of the sale of the consumer's personal information. We do not sell your personal information to third parties.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal data we collect and the specific context in which we collect it.

We may process your personal data because:

- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- To comply with the law

Privacy Shield

Emmre complies with the EU-US and Swiss-US Privacy Shield Frameworks, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union, the United Kingdom and/or Switzerland to the United States. Emmre adheres to and will abide by the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement, and Liability when processing such personal data.

In the context of an onward transfer Emmre has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Emmre shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless Emmre proves that it is not responsible for the event giving rise to the damage.

We commit to resolving complaints about your privacy and our collection and use of your personal data within 45 days of receiving your complaint. If you have any questions or complaints regarding this Privacy Policy you should first submit your inquiry using the contact details below. For any unresolved privacy complaints under the Privacy Shield Principles, please contact our independent third party dispute resolution body, JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit http://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint. The services of JAMS are provided to you free of charge. Under limited circumstances, binding arbitration may be a dispute resolution mechanism if your complaint is not resolved through these channels.

For more information about the Privacy Shield, see the US Department of Commerce's Privacy Shield website located at: https://www.privacyshield.gov. To review the certification on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.

If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

Transfer of Data

Your information, including personal data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal data, to the United States and process it there. You can request to enter a Data Processing Addendum (DPA) to any existing service agreement with us here.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

 "Do Not Track" Signals
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in some web browsers to inform websites that you do not want to be tracked.

Links to Other Sites
Emmre contains links to other sites that are not operated by us. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Use of Emmre
We do not knowingly collect information from anyone under the age of 13. In order to use Emmre, you must be old enough to consent to the collection of your personal data in your country.

Amendments
We may periodically update this policy. We will notify our users about significant changes to this Privacy Policy by sending a notice to the user's primary email address listed with us and by placing a prominent notice in our applications.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Questions

Any questions about this Privacy Policy should be addressed to our support team at support@emmre.com.