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Last Updated: August 1, 2018

Centric Software Privacy Policy

Centric Software, Inc., a California corporation (“Company”, “we,” or “us”) respects the privacy of individuals who visit the Company’s web sites, our customers, and individuals who register to attend the Company’s corporate events or access certain restricted content on our Website.  By using our www.CentricSoftware.com website, any other webpages which we operate, and software and web-based applications that use cookies (collectively the “Website”), or where we post a direct link to this privacy policy (“Policy”), you consent to the collection, use, and disclosure of personal information in accordance with this Policy.  This Policy describes our use and disclosure of the personal information we collect.  If you do not agree with the terms set out herein, please do not use this website.

1. Personal Information

Personal Information,” as used in this Policy, means any information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the person.

By way of example, and not intended to be an exhaustive list, we may collect the following Personal Information:

  • First and last name;
  • Title;
  • Email address;
  • Postal address;
  • Telephone number;
  • Employer information; and
  • Any other Personal Information as may be relevant for the uses identified in Section 3

Personal Information does not include “aggregate” or other non-personally identifiable information.  Aggregate information is information that we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed.  We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes.

2. Collection of Information

Collection of Voluntarily-Provided Information

We collect Personal Information that our users provide to us in a variety of ways.  These include the following:

  • Subscribing to Email Newsletters.
  • Registering for events (including, without limitation, seminars, webinars).
  • Requesting information about our products.
  • Correspondence. If you contact us by e-mail, using a contact form on the Website, or by mail, fax, or other means, we collect the Personal Information contained within, and associated with, your correspondence.
  • Applying for a job.
  • Personal information collected online may be supplemented with information you provide to Centric Software through other Centric Software services, as well as other sources such as trade shows or seminars, and other data appending methods such as spot tags, tracking and cookies as referenced below.

Passive Information Collection

When you visit our Website, some information is collected automatically.  For example, we automatically collect your browser’s Internet Protocol (IP) address, your browser type, the nature of the device from which you are visiting the Website (e.g., a personal computer or a mobile device), the identifier for any handheld or mobile device that you may be using, the actions you take on our Website.  We also may collect information regarding your interaction with e-mail messages, such as whether you opened, clicked on, or forwarded a message.

We may collect this information passively using technologies such as standard server logs, cookies, and clear GIFs (also known as “Web beacons”).  We only collect data using cookies and clear GIFs where you have consented to their use.  Cookies are identifiers that can be sent from a site via your browser to be placed on your computer’s hard drive. Thereafter when you visit a site, a message is sent back to the web server by the browser accessing the site.  You can also control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Website.  We use passively-collected information to administer, operate, and improve the Website, to improve the effectiveness of advertising, and to provide advertisements and other content that is tailored to you.  If we link or associate any information gathered through passive means with Personal Information, or if applicable laws require us to treat any information gathered through passive means as Personal Information, we treat the combined information as Personal Information under this Policy.  Otherwise, we use and disclose information collected by passive means in aggregate form or otherwise in a non-personally identifiable form.

Information from Other Sources

We may receive information about you, including Personal Information, from third parties, and may combine this information with other Personal Information we maintain about you.  If we do so, this Policy governs any combined information that we maintain in personally identifiable format.

3. Purpose and Legal Basis of Processing Personal Information

We use Personal Information to provide the materials that you request; manage our events; enhance, improve, operate, and maintain our Websites, products and services, and other systems; prevent fraudulent use of our Websites, products and services, and other systems; prevent or take action against activities that are, or may be, in violation of our Website Terms of Use, customer agreements, or applicable law; tailor advertisements, content, and other aspects of your experience on and in connection with the products and services we offer; maintain a record of our dealings with you; for other administrative purposes; for processing employment applications; and for any other purposes that we may disclose to you at the point at which we request your Personal Information, and pursuant to your consent.  Occasionally we may use your information to contact you to complete surveys that we use for marketing and quality assurance purposes.

We may also use Personal Information you provide to contact you regarding products, services, and offers, both from ourselves and from third parties, that we believe you may find of interest.  We allow you to opt-out from receiving marketing communications from us as described in the “Choice” section below.

 We process your Personal Information on the basis of your consent, for the performance of a contract to which you (or your company) is a party, and/or as necessary for compliance with our legal obligations.

4. Recipients of Personal Information

Except as described in this Policy, we will not disclose your Personal Information that we collect to third parties without your consent.  We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

Service Providers 

We may disclose Personal Information to third-party service providers (e.g., payment processing, data storage and processing facilities, event venues, marketing companies etc) that assist us in our work.  We limit the Personal Information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such Personal Information.

Where you transmit data to us via email, your enquiry is stored and processed as an email which is hosted by Microsoft. It may also be logged on a CRM system, Salesforce.com.  Our website is hosted by a third-party provider who would also receive your data.  Any data you enter into our website is stored in our CRM system.

Centric Software Affiliates

Centric Software may share Personal Information with other companies in order to work with them, including affiliates of the Centric Software corporate group. For example, Centric Software may need to share Personal Information with other companies within the Centric Software corporate family for customer support, marketing, technical operations and account management purposes.

Business Transfers

Information about our users, including Personal Information, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Information is transferred to one or more third parties as one of our business assets.

For Legal Reasons

We also disclose Personal Information if we believe that doing so is legally required, or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others, or otherwise to help protect the safety or security of our Website and other users of the Website.

We take appropriate steps to safeguard your data as required by law, including those allowed under Article 46 of Regulation (EU) 2016/679.  You may request additional information about such steps by contacting us as described in Section 16 (Contacting Us) below.

We reserve the right to fully use and disclose any information that is not in personally identifiable form.

5. Choice

If you receive commercial e-mail from us, you may unsubscribe at any time by following the instructions contained within the e-mail.  You may also opt-out from receiving commercial e-mail from us, and any other promotional communications that we may send to you from time to time (e.g., by postal mail) by sending your request to us by e-mail or by writing to us at the address given at the end of this policy.

Please be aware that if you opt-out of receiving commercial e-mail from us, it may take up to ten business days for us to process your opt-out request, and you may receive commercial e-mail from us during that period.

6. Personal Information Retention Period

We do not store your Personal Information for more time than necessary. Retention periods may vary depending on the data categories and the processing activities.

Where we are processing and using your Personal Information as permitted by law or under your consent, we will store it (i) only as long as required to fulfill the purposes set out above, (ii) where we have a legitimate interest in using the Personal Information, until you object to our use of the Personal Information, or (iii) where you gave you consent, until you withdraw it.  However, where we are required by applicable law to retain the Personal Information longer or where the Personal Information is required to assert or defend against legal claims, we will retain it until the end of the relevant retention period or until the claims in question have been settled.

7. Access

Our customers have the ability to create user accounts or profiles on our Website for providing software support services, you may have the ability to access and update many categories of personal information that you provide to us by logging in to your account and accessing your account settings.

If you request that we delete your account (via a user settings page, by e-mail, or otherwise), we will do so within a reasonable period of time, but we may need to retain some of your Personal Information in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so. If you are an employee of a Centric Software customer, you may also wish to contact your company’s system administrator for assistance in correcting or updating your information.

8. Customer Data

Centric Software customers may electronically submit data or information into the Centric Software application (“Customer Data”). Centric Software will only have access to such Customer Data in the event the Customer also has engaged Centric Software to provide related services, which may include, but not be limited to, hosting, maintenance and support, or managed services (“Services”).  Where Centric Software has such access, it will not review, share, distribute, or reference any such Customer Data except as provided in the applicable Master License Agreement, Services Agreement, and/or Data Processing Agreement (the “Agreement”), or as may be required by law. In accordance with the Agreement, Centric Software may access Customer Data only for the purpose of providing the Services or preventing or addressing service or technical problems or as may be required by law.

Centric Software acknowledges that you have the right to access your personal information.  If personal information pertaining to you as an individual has been submitted to us by a Centric Software customer and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with our customer directly. Because Centric Software personnel have limited ability to access data our customers submit to our Services, if you wish to make your request directly to Centric Software, please provide the name of the Centric Software customer who submitted your data to our Services.  We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.

9. Links

The Website may contain links to other web sites, products, or services that we do not own or operate.  If you choose to visit or use any Third-Party Sites or products or services available on or through such Third-Party Sites, please be aware that this Policy will not apply to your activities or any information you disclose while using those Third-Party Sites or any products or services available on or through such Third-Party Sites.  We are not responsible for the privacy practices of these Third-Party Sites or any products or services on or through them.

10. Children

Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children.  Our Website, products, and services are not directed to, or intended to be used by, children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13 without obtaining parental consent.  If we learn that we have collected personal information from a child under the age of 13 on our Website, we will delete that information as quickly as possible.  If you believe that we may have collected any such personal information, please notify us as provided in Section 16 (“Contacting Us”) below.

11. International Visitors

If you choose to use the Website from outside the U.S., then you should know that you are transferring your Personal Information outside of your region and into the U.S. for storage and processing. By providing your Personal Information to us through your use of the Website, you agree to that transfer, storage, and processing in the U.S.  Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Website. However, we will take steps to ensure that all information collected through our website and applications is treated securely and in accordance with this Privacy Policy.

12. Security

We use reasonable security measures that are designed to protect personal information from accidental loss, disclosure, misuse, and destruction.  Please be aware, however, that no data security measures can be guaranteed to be completely effective.  Consequently, we cannot ensure or warrant the security of any information that you provide to us.  You transmit information to us at your own risk.

13. Your Rights as a Data Subject

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.

If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.

If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.

You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.

Finally, in some circumstances you can ask us not to reach decisions affecting you using automated processing or profiling.

To submit a request regarding your personal data by email, post or telephone, please use the contact information provided below in the Section labelled “Contacting Us”.

14. Your Right to Complain

 If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. Please find our contact information in Section 16 (“Contacting Us”) below.

While we prefer you contact us directly to enable us to promptly address your concerns.  You have the legal right to contact the local supervisory authority in your country to lodge a complaint.

15. Updates to this Policy

We may occasionally update this Policy.  When we do, we will also revise the “last updated” date at the beginning of the Policy.  Your continued use of our Website after such changes will be subject to the then-current policy.  As may be required by applicable law, if we change this Policy in a manner that is materially less restrictive of our use or disclosure of your Personal Information, we will use reasonable efforts to notify you of the change and to obtain your consent prior to applying the change to any Personal Information that we collected from you prior to the date the change becomes effective.  We encourage you to periodically review this Policy to stay informed about how we collect, use, and disclose personal information.

16. Contacting Us

If you have any questions or comments about this Policy, please contact us using the following contact information:

 Centric Software, Inc.

Attn: Privacy

655 Campbell Technology Pkwy, Ste 200

Campbell CA 95008 USA

privacy@centricsoftware.com

We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above.