Policy last updated: May 2020
We strongly urge you to read this policy and make sure you fully understand it, before you access our Website. By accessing our Websites, you acknowledge that you have read this Policy. If you do not agree with it, then please do not use our Website.
1. Please read carefully!
This Policy describes how Epik, together with its affiliated companies worldwide, collect and use information pertaining to each of our website visitors (each, a “Visitor”, or “you”), in connection with their access to and use of Epik’s websites (including www.Epikso.com and Epikview360.com), web applications and related services (collectively, the “Services”).
The purpose of this Policy is to provide you with a clear explanation of when, why and how we collect and use your personal information, as well as an explanation of your statutory rights. This Policy is not intended to override the terms of any contract you have with us, nor any rights you might have under applicable data privacy laws.
If you have any questions or concerns regarding this policy, please contact us at email@example.com.
2. What information do we collect?
2.1. Visitor and user information
We collect two types of information regarding our visitors and users:
- Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
- Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third-party accounts (such as the e-mail or username for a connected Google or Facebook account), scanned identification documents provided to us (such as an ID card, driver’s license, passport or official company registration documents), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.
We collect such information regarding our users and visitors, job applicants and anyone else who may provide it to us.
2.3. Epik jobs applicant information
We also collect information that is provided to us by Epik jobs candidates (“Applicants”), when they apply to any of the open positions published at www.epikso.com, by e-mail or otherwise (as further described in Section 6 below).
3. How do we collect such information?
There are two main methods we use:
We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website or download information and content, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed in Section 7 below, including through the use of “cookies” and other tracking technologies, as further detailed in Section 8 below.
We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you request information about our business and/or when you contact us directly by any communication channel.
We also collect information from third party sources as described in Section 7 below.
4. Why do we collect such information?
We collect such Non-personal and Personal Information for the following purposes:
- To provide and operate the Services;
- To further develop, customize and improve our Services, based on Visitors’ common or personal preferences, experiences and difficulties;
- To be able to contact our Visitors with general or personalized service-related notices and promotional messages (as further detailed in Section 10 below);
- To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we may use to provide and improve our respective services;
- To enhance our data security and fraud prevention capabilities;
- To consider Applicants’ candidacy for working at Epik (as further detailed in Section 6 below); and
- To comply with any applicable laws and regulations.
We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:
- Our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you, or
- Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or
- Our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Services by identifying user trends and the effectiveness of Epik campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
We also collect and use information in order to contact our visitors, users, and job applicants, and in order to comply with the laws applicable to us.
5. Where do we store your information?
Epik Visitors’ Personal Information may be maintained, processed and stored by Epik and our affiliates and service providers in the United States of America, Australia and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
Epik affiliates and service providers that store or process your Personal Information on Epik’s behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
Epik’s data storage providers are contractually committed to protect and secure your data.
Data Localisation Obligations: If you reside in a jurisdiction that imposes “data localization” or “data residency” obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so.
You acknowledge that while doing so, we may continue to collect, store and use your Personal Information elsewhere, including in the United States of America as explained above.
6. Epik jobs applications
Epik welcomes all qualified Applicants to apply to any of the open positions published at firstname.lastname@example.org, by sending us their contact details and CV (“Applicants Information”) via the relevant Position Application Form on our Website, or through any other means provided by us.
We understand that privacy and discreetness are crucial to our Applicants, and are committed to keep Applicants Information private and use it solely for Epik’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).
Please note that Epik. may retain Applicants Information submitted to it for no longer than two years after the applied position has been filled or closed. This is done so we can re-consider Applicants for other positions and opportunities at Epik; so we can use their Applicants Information as a reference for future applications submitted by them; and if the Applicant is hired, for additional employment and business purposes related to employment.
If you previously submitted your Applicants Information to Epik, and now wish to access it, update it or have it deleted from Epik’s systems, please contact us at email@example.com.
We will use such information solely for our internal recruitment, employment and business purposes.
7. Sharing personal information with third parties
Epik may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
7.1. Third party services:
Epik has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cybersecurity services, billing and payment processing services, fraud detection and prevention services, web analytics, email distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”).
Such Third Party Services may receive or otherwise have access to our Visitors’ Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes.
Note that while our Services may contain links to other websites or services, we are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave our Services and read the privacy statements of each and every website and service you visit before providing your Personal Information. This Policy does not apply to such linked third -party websites and services.
The information may be shared solely in accordance with this policy.
7.2. Law enforcement, legal requests, and duties
Where permitted by local data protection laws, Epik may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
7.3. Protecting rights and safety:
Epik may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of Epik, any of our Users or any member of the general public, with or without notice to you.
7.4. Social media features and framed pages:
Our Services include certain Social Media features and widgets, single sign-on features, such as the “Facebook Connect”, the “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
7.5. Epik subsidiaries and affiliated companies:
We may share Personal Information internally within our family of companies, for the purposes described in this Policy. For example, we may share your Personal Information with Epik, our US and other subsidiaries, in the course of facilitating and providing you with our Services. In addition, should Epik or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such an event. If we have good faith that such change in control might materially affect your Personal Information stored with us, we will notify you via email and/or a prominent notice on our Websites of this event and certain choices you may have regarding your Personal Information.
To clarify, Epik may share your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so. Moreover, Epik may transfer, share, disclose or otherwise use Non-personal Information in its sole discretion and without the need for further approval.
Epik, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags, and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Visitors’ preferences, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.
Please note that Third Party Services placing cookies or utilizing other tracking technologies through our Services may have their own policies regarding how they collect and store information. Such practices are not covered by this Policy and we do not have any control over them.
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media), monitoring performance of our services and marketing campaigns, and generally providing and improving our services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by Epik, and we, therefore, cannot ensure its accuracy, completeness or availability).
Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
Clear Gifs: We and certain Third Party Services may employ a software technology called “clear gifs” (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however, are not stored on your device, but instead embedded within our Services.
Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies. Additional information about managing Flash cookies is available here.
(Please note that this website is not provided by Epik, and we, therefore, cannot ensure its accuracy, completeness or availability).
User Data Supplementation: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and Services that may be of interest to you. Where we obtain your Personal Information from these third parties, we ensure that such parties are contractually committed to informing you that your Personal Information will be disclosed to us and we take steps to ensure the accuracy of your Personal Information before using it. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.
These technologies are used mostly for stability, security, functionality, performance and advertising purposes.
You may block, opt-out of or otherwise manage such tracking technologies by yourself, through your browser settings or other sources – but please note that this may adversely affect the way you experience our services.
9. Communications from Epik
9.1. Promotional messages:
We may use your Personal Information to send you promotional content and messages by email, text messages, direct text messages, marketing calls and similar forms of communication from Epik through such means.
If you do not wish to receive such promotional messages or calls, you may notify Epik at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
We take steps to limit the promotional content we send you to a reasonable and proportionate level and to send you information which we believe may be of interest or relevance to you, based on your information.
You can easily opt-out of receiving promotional messages by contacting us or unsubscribing.
9.2. Service and billing messages:
Epik may also contact you with important information regarding our Services, or your use thereof.
For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are not being able to opt-out of receiving such Service and Billing Messages unless you are no longer an Epik Visitor or client.
We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages.
10. Your rights in relation to your personal information
It is imperative that you have control over your Personal Information. That’s why Epik is taking steps to enable you to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are an Epik Visitor, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us, or contact us for any information.
We will make all reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfill your request), subject to legal and other permissible considerations.
You may request to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information you have stored with us. Just send us an e-mail. We will respond to your requests within a reasonable timeframe.
11. Questions and complaints
If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if you believe we have not complied with this Policy or applicable data protection laws, please contact us – our details are set out at the end of this Policy.
Our Privacy team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.
We take every privacy complaint seriously and will make all reasonable efforts to resolving your complaint promptly. Our target response time is 30 days.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a complaint with your local supervisory authority for data protection.
You can file a complaint with your local supervisory authority for data protection at any time; however, we recommend that you contact us first so we can try to resolve it.
12. Data retention
We may retain your Personal Information even after you cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests. Where your Personal Information is no longer required we will ensure it is securely deleted or anonymized.
Epik has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. We regularly monitor our systems for possible vulnerabilities and attacks and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ privacy.
Regardless of the measures and efforts are taken by Epik, we cannot and do not guarantee the absolute protection and security of your Personal Information.
If you have any questions regarding the security of our Services, you are welcome to contact us at firstname.lastname@example.org
14. Updates and interpretation
Unless stated otherwise, our most current Policy applies to all information that we have about you, with respect to our Websites.
15. California consumer privacy act (“CCPA”) -
- If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the CCPA).
A. Categories of personal information we collect
Throughout this Policy, we discuss in detail the specific pieces of personal information we collect from and about our Visitors. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories we collect are:
- identifiers (such as name, address, email address);
- internet or other network or device activity (such as browsing history or Service usage);
- general geolocation information (e.g., your approximate location based on IP address);
- professional or employment related data (e.g., your business contact information);
- biometric information (e.g., if you participate in a sales call and do not opt out of call recording);
- inference data about you (e.g., the additional Service features we think would be of most interest to you);
- legally protected classifications (such as gender); and
- other information that identifies or can be reasonably associated with you.
We do not collect:
- commercial information (such as transaction data);
- financial data (such as credit card information collected by our payment processors on our behalf); or
- physical characteristics or description.
B. How we use and share these categories of personal information
We use and share the categories of personal information we collect from and about you consistent with the various business purposes discussed in this Policy’s section(s).
Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity.
C. Your California privacy rights
CCPA rights disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:
- Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. Such information is also set forth in this Policy.
- Provide access to and/or a copy of certain personal information we hold about you.
- Delete certain personal information we have about you.
- Provide you with information about the financial incentives that we offer to you, if any.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, verifying your name and email address. You are also permitted to designate an authorized agent to submit certain requests on your behalf. We may also follow up with you to verify your identity before processing the authorized agent’s request.
If you are a California resident, and you would like to exercise any of your rights under California law with respect to your personal information, please submit your request by contacting us at email@example.com.
Shine the Light Disclosure. California’s “Shine the Light” law gives California residents of California the right under certain circumstances to request information from entities regarding the manner in which they share certain categories of personal information (as defined in that law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
16. Contacting Epik
If you have any questions about this Policy or wish to exercise any of your rights as described in Section 10, please contact the Privacy team at firstname.lastname@example.org. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Policy.