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SpringCM Inc. (“SpringCM,” “us” or “we”, or “our”) is serious about protecting the privacy of the Personal Information belonging to or submitted to us by our Customers and Visitors, each as defined below. Our success is based on the trust others place in us to process and store their critical information. We work hard to earn and maintain that trust.
Privacy Certification – Switzerland; EU
U.S.-Swiss Safe Harbor Framework
SpringCM participates in and has certified its compliance with the U.S.-Swiss Safe Harbor Framework regarding the collection, transfer, use and retention of Personal Information from Switzerland. SpringCM has certified that it adheres to the U.S.-Swiss Safe Harbor Privacy Principles of notice, choice, onward transfer, access, security, data integrity, and enforcement. To learn more about the U.S.-Swiss Safe Harbor program, please visit the U.S. Department of Commerce’s website at https://build.export.gov/main/safeharbor/swiss/eg_main_018519. To view SpringCM’s certification, please see https://safeharbor.export.gov/swisslist.aspx.
EU-U.S. Privacy Shield Framework
SpringCM also participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework (the “Privacy Shield”) regarding the collection, transfer, use and retention of Personal Information from the EU. SpringCM is committed to protecting the privacy of Personal Information received from the European Union in accordance with the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability. To learn more about the Privacy Shield, please visit the U.S. Department of Commerce’s website at https://www.privacyshield.gov/welcome. To view SpringCM’s certification, please see https://www.privacyshield.gov/list.
Under the Privacy Shield, SpringCM is responsible for the processing of Personal Information it receives from the EU, and subsequently transfers to a third party acting as an agent on its behalf. SpringCM may be liable for the failure of such a third party to adhere to the Privacy Shield Principles, unless SpringCM proves that it is not responsible for the event giving rise to the damage.
Pursuant to the Privacy Shield, SpringCM. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, SpringCM, Inc. may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If SpringCM is processing or storing your Personal Information subject to the Privacy Shield on behalf of a Customer of SpringCM or otherwise, you have the right to access your Personal Information. If you have any privacy or data use questions or concerns, please contact us as described in the “Contact SpringCM” section below. SpringCM will respond within 45 days. If, despite our efforts, we have not addressed your privacy or data use concern satisfactorily, you may submit it to our U.S.-based third party dispute resolution provider, TRUSTe (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
If you are an existing or prospective SpringCM Customer and wish to discuss SpringCM’s agreement to the E.U. Standard Clauses for data protection, please contact us as described in the “Contact SpringCM” section below.
What Information Do We Collect and How Do We Use It?
The information collected by SpringCM through our Site is not ordinarily acquired in a form or manner that reveals Personal Information. However, Personal Information may be supplied to SpringCM by our Customers or Visitors through the Site or our Services, including contact information (such as name, address, telephone number, e-mail address and company name). We may use this information to create an account for you, fulfill your request for a demo, subscribe you to our newsletters, reply to your contact request, process billing or to otherwise take action related to the purpose for which you supplied it. This information is generally entered into fields in a Customer Order Form or MSA 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 you supplied during this process may be used to track details about those purchases. In addition, when you download or use our mobile applications or other Services, we automatically collect information on the type of device you use, the operating system version and the device identifier.
In our mobile applications, use of the upload functionality requires access to the photo album of the device. Applications developed for the Apple iOS may require location services to be enabled on the user’s device in order for the app to access location information for security reasons. SpringCM does not collect or store your geo-location information. If you do not wish to enable location services in our mobile applications, you may use the application without the upload functionality or discontinue the use of the mobile application altogether. Be advised that when you download the SpringCM mobile application from Apple’s App Store, Google Play or Amazon AppStore for Android, the companies that make those sites available state their own privacy practices on their respective sites. SpringCM has no control over and no responsibility for the privacy practices of those third parties.
SpringCM’s processing and use of Personal Information contained within Customer Content (as defined in an applicable MSA) transmitted by our Customers to SpringCM for processing using our Services, is limited to such processing and use as the Customer directs and controls through our Services. It generally will not be accessed by SpringCM except to the extent necessary in connection with addressing technical issues related to our Services, as instructed by the applicable Customer, as necessary to fulfill our contractual obligations to the Customer, or as otherwise required by law. Information Sharing
In all circumstances involving the onward transfer of Personal Information from Switzerland or the EU, SpringCM will adhere to principles of the U.S.-Swiss Safe Harbor Framework and the EU-U.S. Privacy Shield Framework, as applicable.
The web servers used to operate our Site collect certain data pertaining to the type of device and equipment and communications methods 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, among other things, to facilitate Site operation and system administration, to generate aggregate, non-personally identifying statistical information, and to improve the performance of the Services made available on the Site. We may combine this automatically collected log information with other information we collect about you or which you provide to us. We do this to improve the Site and our Services and to improve our marketing, analytics, and the functionality of our technology.
SpringCM may also retain the content of and metadata regarding any correspondence you may have with SpringCM or its customer service representatives. This information helps SpringCM improve the Site and our Services, and more effectively and efficiently respond to both current and future inquiries.
SpringCM and its partners use “cookies” (small text files stored on your computer), or similar technologies to help analyze trends, administer our Site, track users’ movements around the Site, and track and customize your access to and use of the Site and the Service. Cookies store and retain information that helps us recognize you on subsequent visits to the Site. Cookies may also store any login or ID and the associated password you use to access the Services, which information is stored in encrypted form. Most popular Internet browsers can be configured to reject cookies and delete those previously accepted. However, this may prevent you from taking full advantage of the Site’s content and the Services available on the Site. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
We partner with third parties to either display advertising on our Site or to manage our advertising on other websites. Our third party partners may use technologies such as cookies tags and scripts, as described above, to gather information about your activities on our Site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish not to have this information used for the purpose of serving you interest-based ads, you may opt out by clicking here (or if located in the European Union click here). Please note that your browser must be set to accept cookies and not delete them upon closing it in order for these opt out services to work. These opt out services are not operated by SpringCM and SpringCM has and will have no responsibility or liability for their proper operation. Please also note that this does not opt you out of being served ads altogether. You will continue to receive generic ads.
We receive permission to post testimonials that include Personal Information prior to posting. If you have provided a testimonial and wish that it be removed from our Site, please contact us at firstname.lastname@example.org or as otherwise described in the “Contact SpringCM” section below.
Our Site offers publicly accessible blogs or discussion forums. Please be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Information or postings from our blog or discussion forums, please contact us at email@example.com or as otherwise described in the “Contact SpringCM” section below. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
Mobile Tracking Technologies
We use mobile analytics software to allow us to better understand how our Customers use our mobile applications to connect to their SpringCM accounts from their mobile phones (or other mobile devices). This software may record information such as how often you use the mobile applications, the events that occur within the applications, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any Personal Information you transmit using the mobile application.
Social Media Widgets
Our Site includes “social media features” and “widgets” such as the “Share This” button or interactive mini-programs that run on our Site. These features and widgets may collect your IP address, which page you are visiting on our Site, and may place a cookie on your device to enable them to function properly. Social Media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features and widgets are governed by the privacy policies of the companies providing them.
What Choices Do You Have? / Opting Out
We communicate with our Customers on a regular basis via e-mail, 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 notices regarding payments, or to send notices and other disclosures as required by law. Generally, Customers cannot opt out of informational communications relevant to their accounts.
Upon request SpringCM will provide you with information about whether we hold or process any of your Personal Information on behalf of a third party. To request this information please contact us at firstname.lastname@example.org or as otherwise described in the “Contact SpringCM” section below.
To keep your Personal Information accurate, complete and current, please contact us via one of the methods specified below. We will make reasonable efforts to update your Personal Information that you submit. The sender of any communications to SpringCM is responsible for the content and information contained therein, including its accuracy and truthfulness.
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 affiliated companies by simply sending such a request to us in writing at the contact information provided below. In addition, you may follow the unsubscribe instructions included in each promotional e-mail. Once you opt out, we will honor your choice until you inform us otherwise. All requests made by Customers or Visitors to SpringCM to update or delete any Personal Information shall be responded to within a reasonable period not to exceed 30 days. Please note that opting out of behavioral advertising, i.e., advertising based upon your browsing activities and interests, requires that you use the opt out methods described in the “Behavioral Advertising” section above.
Personal Information Contained Within Customer Content
The Customer Content which SpringCM’s Customers may transmit, store or process using our Services may contain the Personal Information of individuals with whom SpringCM has no direct relationship. All such Customer Content is under the control of the applicable SpringCM Customer and the Customer is ultimately responsible to the individuals whose Personal Information it collects, uses, transmits, stores or processes using our Services.
SpringCM works with its Customers to help them provide notice to their customers concerning the purposes for which they use our Services to process the Personal Information of their customers. If you are a customer of one of our Customers or other individual who seeks access to, or who seeks to correct, amend, or delete inaccurate Personal Information pertaining to you which you believe is processed by SpringCM for one of our Customers, you should direct your inquiry to the applicable SpringCM Customer (the data controller), i.e., the party with which you have a direct relationship. If our Customer requests SpringCM to remove the data, we will respond to their request within 30 days. If you are subject to the protections of the Privacy Shield, you will have the rights described in the “EU-U.S. Privacy Shield Framework” section above.
How Do We Protect Your Information?
SpringCM recognizes that protecting the corporate and Personal Information entrusted to us by our Customers is essential to maintaining that trust. For this reason, we provide three layers of security for your Customer Content and Personal Information: physical, application, and network. The physical layer is protected by need-to-know authorization provided only to the appropriate operations individuals. Additionally, the servers are caged within a room protected by secure access procedures. The application layer is secured with VeriSign’s Site Trust 128 bit SSL encryption technology so all communication with the Site is locked. The network layer is protected by industry-leading firewall technology and administered real-time to provide timely security patching. This layer is also monitored by intrusion-detection systems designed to detect unauthorized access. These safeguards are intended to protect Customer Content and Personal Information and to ensure, to the extent possible, 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.
In the event you provide SpringCM with any suggestions, enhancement requests, recommendations, product or services ideas for improvements, features or any other feedback (collectively, “Feedback”), SpringCM shall have a royalty-free, worldwide, irrevocable, perpetual license to use, copy, modify, distribute and incorporate any and all of the foregoing into the SpringCM Services and/or any other products and services, and to re-sell, re-license and otherwise freely commercialize the foregoing and exercise any and all rights it deems useful or necessary with regard thereto, without limitation and without remuneration, attribution or liability to you.
If you are a SpringCM Customer, your existing MSA with SpringCM governs your use of the SpringCM Services. With respect to all other users of this Site, the following shall apply, and your use of SpringCM’s Site constitutes your agreement to the following:
SPRINGCM DOES NOT WARRANT THAT THIS SITE WILL MEET ANY USER’S REQUIREMENTS OR THAT ITS USE OR AVAILABILITY WILL BE UNINTERRUPTED OR ERROR FREE. THIS SITE AND THE INFORMATION AVAILABLE ON OR THROUGH IT IS PROVIDED “AS IS,” WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR OTHERWISE.
IN NO EVENT SHALL SPRINGCM, ITS LICENSORS, EMPLOYEES, AGENTS, DISTRIBUTORS, MARKETING PARTNERS, RESELLERS, PARENT, AFFILIATES OR SUBSIDIARIES BE LIABLE FOR ANY CONSEQUENTIAL, INCIDENTAL, INDIRECT, SPECIAL, PUNITIVE OR ANY OTHER DAMAGES, INCLUDING DAMAGES CONSISTING OF OR RESULTING FROM LOST PROFITS, COSTS OF DELAY, FAILURE OF DELIVERY, BUSINESS INTERRUPTION, LOSS, DAMAGE, DELETION, ALTERATION, DISCLOSURE, UNAUTHORIZED ACCESS TO OR FAILURE TO STORE DATA OR CUSTOMER CONTENT, NOR LIABILITIES TO THIRD PARTIES ARISING FROM ANY SOURCE, REGARDLESS OF THE NATURE OF THE CLAIM, EVEN IF SPRINGCM HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
Reporting Copyright Violations – Copyright Agent – Notice and Procedure for Notification of Claimed Copyright Infringement Pursuant to 17 U.S.C. Sec. 512 of the U.S. Copyright Law
If you believe that your copyrighted work has been copied and is accessible on any network, service or product provided by SpringCM in a way that constitutes copyright infringement, you may notify us as described below. This procedure and the following information is provided exclusively for this purpose. Any other inquiries will not receive a response through this process.
Please note that your notification must be in writing and contain substantially the following information to be effective:
Written notification must be submitted to SpringCM’s Designated Agent: SpringCM Inc., Attn: Greg Buchholz, Copyright Agent, 180 North LaSalle Street, 6th Floor, Chicago, IL 60601; Telephone: (312) 881-2018; Facsimile: (312) 253-8215; E-mail: email@example.com.
Note: By submitting your notification to SpringCM’s Designated Agent, you represent, under penalty of perjury, that the above information is accurate, that you are the copyright owner or are authorized to act on such person's behalf, and that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law. In addition, be advised that under U.S. Copyright law, 17 U.S.C. Sec. 512(f) [Misrepresentations], any person who knowingly materially misrepresents in the notification described above that material or activity is infringing shall be liable for any damages, including costs and attorneys’ fees, incurred by the alleged infringer, by any copyright owner or copyright owner’s authorized licensee, or by a service provider, e.g., SpringCM, who is injured by such misrepresentation, as the result of the service provider relying upon such misrepresentation in removing or disabling access to the material or activity claimed to be infringing, or in replacing the removed material.
Upon receipt by SpringCM’s Designated Agent of the required notification containing the information as outlined in 1 through 6 above, SpringCM shall take reasonable steps to:
Counter Notification: If you are affected by the aforementioned notification of claimed infringement, you may provide a counter notification to SpringCM. To be effective, a Counter Notification must be a written communication provided to SpringCM’s Designated Agent that includes substantially the following:
Upon receipt of a Counter Notification from the affected SpringCM Customer containing the information as outlined in 1 through 4 above, SpringCM shall:
Effective date of this version: September 28, 2016.Copyright © SpringCM Inc. All rights reserved.