Version 2.6 - August 2017
Your privacy is important to us at Aptible. We want to be clear how we use your information, and the ways in which you can protect your privacy.
- What information we collect and why we collect it.
- How we use that information and when we disclose it.
- How to access and update your information.
- The steps we take to protect your information.
Information We Collect
1. Information you provide to us
We collect the following information:
Content: We collect and store content that you create, input, submit, post, upload, transmit, or store in the process of using our Services, including information from end users of any application that you develop using our Services and/or that we host on your behalf. Such content may include any personal or other sensitive information submitted using our Services, such as personal health information, and other information such as source code or regulatory compliance materials.
Other submissions: We collect other data that you may submit to our Services or us directly, such as when you request customer support or communicate with us via email or social media sites.
2. Information we collect from your use of our Services
Web Logs and Analytics Information: We record certain information and store it in log files when you interact with our Services. This information may include Internet protocol (IP) or other device addresses or ID numbers as well as browser type, Internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, your mobile carrier, and system configuration information. We and our analytics providers also collect and store analytics information when you use our Services to help us improve our Services.
3. Information we collect from other sources
Information from third party services: We may obtain information, including personal information, from third parties such as our partners and service providers, and combine it with other information we collect from you.
How We Use Information We Collect
We may use the information we collect for a variety of purposes, including to:
- Provide, operate, maintain, improve, personalize, and promote our Services;
- Develop new products, services, features, and functionality;
- Enable you to access and use our Services;
- Process and complete transactions, and send you related information, including purchase confirmations and invoices;
- Communicate with you, including responding to your comments, questions, and requests; providing customer service and support; providing you with information about services, including technical notices, updates, security alerts, administrative messages, or advertising or marketing messages; and providing other news or information about us and our select partners;
- Monitor and analyze trends, usage, and activities in connection with our Services; and
- Investigate and prevent fraudulent transactions, unauthorized access to our Services, and other illegal activities.
We may also use the information we collect for other purposes about which we notify you.
Information Sharing and Disclosures
We may share your information in the following ways:
With your express consent: We will share your personal information with companies, organizations, or individuals outside of Aptible when we have your consent to do so.
Your use: When you use our Services, certain features allow you to make some of your content accessible to the public or other users of the Services. We urge you to consider the sensitivity of any information prior to sharing it publicly or with other users.
Access by your Aptible administrator: Your Aptible account owner or HIPAA Security Officer may be able to:
- Access information in and about your Aptible account;
- Disclose, restrict, or access information that you have provided or that is made available to you when using your Aptible account, including your content; and
- Control how your Aptible account may be accessed or deleted.
Service Providers, Business Partners and Others: We may share your information with service providers and other third parties who perform services on our behalf, such as infrastructure, analytics, marketing, and advertising services. We provide your payment information to our service providers for payment processing and verification. Service providers such as analytics providers may collect information about your online activities over time and across different online services when you use our Services.
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights: We may disclose your information (including your personal information) to a third party if:
- We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request;
- To enforce our agreements, policies and terms of service;
- To protect the security or integrity of Aptible’s products and services;
- To protect the property, rights, and safety of Aptible, our customers or the public from harm or illegal activities;
- To respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person; or
- To investigate and defend ourselves against any third-party claims or allegations.
Business Transfers: We may share or transfer your information (including your personal information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We will notify you of such a change in ownership or transfer of assets by posting a notice on our website.
Aggregate or Non-identifying Data: We may share aggregate or other non-personal information that does not directly identify you with third parties in order to improve the overall experience of our Services.
The Choices You Have With Your Information
You may decline to share certain personal information with us, in which case we may not be able to provide to you some of the features and functionality of our Services. You may update or correct your personal information at any time by accessing the account settings page on the website or within our platform. You may opt out of receiving promotional communications from Aptible by using the unsubscribe link within each email. Even after you opt out from receiving promotional messages from us, you will continue to receive administrative messages from us regarding the Services.
Our Services are not directed to individuals under 13. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us at email@example.com.
The core Enclave and Gridiron APIs are are hosted in the United States. You may choose to run Enclave stacks in non-U.S. regions, such as the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law. Please note that when you use the core Enclave and Gridion APIs, you are transferring your information outside of those regions to the United States for storage and processing. By providing your information, you consent to any transfer and processing in accordance with this Policy.
EU-U.S. Privacy Shield and U.S.-Swiss Safe Harbor Compliance
Aptible, Inc. is a participant in the U.S. Department of Commerce’s EU-U.S. Privacy Shield and Swiss Safe Harbor programs, and has certified that we adhere to the EU-U.S. Privacy Shield and U.S.-Swiss Safe Harbor Privacy Principles. Aptible is subject to the investigatory and enforcement powers of the Federal Trade Commission.
For more information about the EU-U.S. Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website.
For more information about U.S.-Swiss Safe Harbor and to view our certification, visit the U.S. Department of Commerce’s Safe Harbor website.
EU-U.S. Privacy Shield Onward Transfers
For personal data transferred from the EU, if we transfer your personal data to a third party, we will ensure that the third party is contractually obligated to process your data only for limited, specific purposes consistent with this policy. We will also ensure that the third party will apply the same level of protection to that data as the EU-U.S. Privacy Shield Principles and will notify us if it makes a determination that it can no longer meet this obligation. Aptible may be potentially liable if these requirements are not met.
Complaints, Questions, and Arbitration
In compliance with the EU-U.S. Privacy Shield and U.S.-Swiss Safe Harbor Principles, we strive to resolve all complaints about privacy and the collection or use of customer information. If you have questions about our participation in the Privacy Shield or Safe Harbor programs or have a complaint, please send an e-mail to firstname.lastname@example.org.
Under the Privacy Shield and Safe Harbor programs, any unresolved privacy complaints can be referred to an independent dispute resolution mechanism. We use the International Centre for Dispute Resolution®/American Arbitration Association®. If you feel that we have not satisfactorily addressed your complaint, you can visit the ICRD/AAA website at https://apps.adr.org/webfile/ for more information on how to file a complaint. In some cases, you may be able to invoke binding arbitration.
California Privacy Rights
California Civil Code Section 1798.83 permits Aptible customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at email@example.com.
Please contact us with any questions or comments about this Policy, your personal information, our use and disclosure practices, or your consent choices by email at firstname.lastname@example.org.