Privacy Policy

Overview

SpringCM Inc. (“SpringCM,” “us,” or “we”) is serious about protecting the privacy of our Customers’ and Visitors’ Personal Information. Our success is based on others entrusting their critical information to us. We work hard to earn and maintain that trust. SpringCM’s privacy practices reflect current industry standards and we abide by the laws in the countries in which we do business. This Privacy Policy applies to our web site at www.springcm.com (the “Site”). It describes our privacy practices regarding Personal Information collected from or provided by visitors (“Visitors”) to our Site and our customers (“Customers”) who use the products or services provided through our Site (collectively, the “Services”). This Privacy Policy is incorporated into and is a part of the Terms of Use of our Site. Visitors and Customers are sometimes referred to herein as “you.” “Personal Information” means any information relating to an identified individual or which can reasonably be used to identify an individual, such as an individual’s name, address, e-mail address, social security number, driver’s license (or government-issued identification number) or financial account information. Personal Information does not include information that is encoded or anonymized, publicly available information that has not been combined with non-public personally identifying information, or personally identifying information that may be contained in a Customer document or other data set uploaded by a Customer for storage and/or access using SpringCM’s services or platform. SpringCM maintains the confidentiality and security of each Customer’s data, which may contain Personal Information to the extent included therein by such Customer, pursuant to the applicable SpringCM Subscription Agreement between SpringCM and such Customer.

SpringCM abides by the Safe Harbor framework as set forth by the United States Department of Commerce regarding the collection, use and retention of information collected from individuals in the European Union by this Site. For more information regarding the Safe Harbor framework, please see http://export.gov/safeharbor/. SpringCM’s Safe Harbor Certification may be found at http://export.gov/safeharbor/eg_main_018236.asp. The foregoing URL’s are controlled by the United States Department of Commerce, not SpringCM, and may be subject to change. For purposes of European Union data protection law and regulations, customers who upload documents and data using the SpringCM services agree that they are the “data controller” and SpringCM is the “data processor” for purposes of such European Union laws and regulations.

1. Consent; Changes to Privacy Policy

Please note that by using this Site, you consent to the collection and use of Personal Information by SpringCM and the authorized third parties described in Section 4 as described in this Privacy Policy.

From time to time, SpringCM may change its privacy practices because of changes in applicable legal or regulatory requirements, the business or business practices of SpringCM or other reasons. Such changes shall become effective within thirty (30) days of the posting of a revised Privacy Policy on this Site. Your continued use of this Site following the posting of changes to this Privacy Policy will mean that you accept those changes.

2. What Information Do We Collect?

The information collected by SpringCM is not ordinarily acquired in a form or manner that permits the identification of an individual’s Personal Information by SpringCM. Notwithstanding the above, Personal Information may be supplied to SpringCM by our Customers. SpringCM collects various types of information from our Customers, including basic contact information (such as name, address, telephone number, e-mail address and company name), as well as billing information. This information is generally entered into fields in a Customer Order Form or Subscription Agreement and enables the Customer to take full advantage of the Services we offer. Should you inquire about or purchase any SpringCM Services utilizing the Site, the information that you supplied during this process may be used to track details about those purchases.

As with many other web sites, the web servers used to operate the Site collect certain data pertaining to those that access the Site and the equipment and communications method that are used to access the Internet and the Site. This data does not contain or constitute Personal Information, as it does not readily identify the individual user. It does reveal such things as the Internet protocol (IP) address assigned to your computer, pages accessed on the Site or immediately prior to visiting the Site, and the length of time you spent at the Site. This information is collected to, among other things, facilitate Site operation and system administration, to generate aggregate, non-personally identifying statistical information, and to improve performance of the Services made available on the Site.

SpringCM may also retain the content of and metadata regarding any correspondence you may have with SpringCM or its customer service representatives, regardless of the mode of communication by which such correspondence was made. This information helps SpringCM to improve the Site and the content and Services offered on the Site, and to more effectively and efficiently respond to both current and future inquiries.

SpringCM uses “cookies” (small text files stored on your computer) to help track and customize your access to and use of the Site. Cookies store and retain information that helps us recognize you on subsequent visits to the Site. Cookies may also store any login or ID assigned to you by SpringCM and the associated password, which information is stored in encrypted form. Most popular Internet browsers allow you to configure the browser so as not to accept cookies. However, setting the browser to reject cookies may prevent you from taking full advantage of the Site’s content and the Services available on the Site.

3. How Do We Use The Information That We Collect?

We may share Personal Information with our affiliated companies who may use it to respond to your inquiries, process orders, assist us in providing Services or to help improve our Services. We may also share Personal Information with business partners, service vendors, authorized third-party agents or contractors in order to provide the Services or a requested transaction, including processing orders, processing credit card transactions, hosting web sites, hosting event and seminar registration and providing customer support, or providing you with information regarding Services that may be of interest to you and for other legitimate and lawful business purposes of SpringCM.

We only provide these third parties with the minimum amount of Personal Information necessary for the authorized purpose and such third parties are not permitted to use your Personal Information for any other purpose. We do not sell or rent Personal Information to third parties for marketing purposes.

4. What Choices Do You Have? / Opting Out

We communicate with our Customers on a regular basis via email, and we may also communicate by phone to resolve Customer complaints or investigate suspicious transactions. We may use your e-mail address to confirm your opening of an account, to send you notice of payments, or to send notices and other disclosures as required by law. Generally, Customers cannot opt out of informational communications relevant to their accounts.

Customers may update at any time their user and account information and preferences stored on the Site or provided during registration.

Customers and Visitors may also ask us at any time to remove their name from our list of Site users who wish to receive e-mail advertisements from SpringCM and our affiliates by simply sending such a request to us in writing at the contact information provided below. Once you opt out, we will honor your choice until you inform us otherwise.

Notwithstanding anything else in this Privacy Policy, including any “opt out” instructions we receive from you, we may also disclose Personal Information without notifying you in the following circumstances: (i) in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; (ii) when we believe it necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our or our Terms of Use or Subscription Agreement with you, and/or to protect our rights and property or those of others with which we do business; or (iii) when we sell, buy, merge or partner with other companies or businesses, where user information may be among the transferred assets or disclosed information.

5. How Do We Protect Your Information?

SpringCM places a high value on the corporate and personal data you entrust to us. For this reason, we secure your company data and Personal Information at three levels: physical, application, and network layers. The physical layer is protected by need-to-know authorization by only the appropriate operations individuals. Additionally, the servers are caged within a room only accessible through biometric scanning. The application layer is entirely secured with VeriSign’s Site Trust 128 bit SSL encryption technology so all communication with the website is locked. The network layer is protected by industry-leading firewall technology and administered real-time to ensure timely security patching. This layer is also monitored by intrusion-detection systems to ward off unauthorized access. These safeguards are intended to protect your data and Personal Information and to ensure the proper and legal use of the Site. However, no security system is impenetrable and no one can guarantee that any information will be totally secure.

6. Linked Sites

For your convenience, some hyperlinks may be posted on the Site that link to other web sites not under the control of SpringCM. We are not responsible for these other web sites and this Privacy Policy does not apply to the privacy practices of those sites. In addition, when you initiate a transaction on a web site that our Site links to, even if you reached that site through our Site, the information that you submit to complete that transaction becomes subject to the privacy practices of the owner of that linked site. You should read their privacy policies to understand how they use and protect personally identifying information and other data that they collect. SpringCM is not responsible for the privacy or information practices of its suppliers or any third party web sites.

Who Can You Contact For More Information?

Please direct any other questions, inquiries or complaints regarding our privacy practices or this Privacy Policy to SpringCM at support@SpringCM.com or by our customer service line at 877-362-7273 or 312-881-2026.

Acknowledgement

YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND AND CONSENT TO THE PRIVACY PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE TERMS OF USE REFERENCED HEREIN.

Revised 03/05/10