Namely Privacy Policy

This Privacy Policy describes the policies and procedures of Namely, Inc. (“Namely”, “we”, “our” or “us”) on the collection, use and disclosure of your information on namely.com (the “Site”), the services, features, content or applications we offer (collectively with the Site, the “Services”) and our mobile application: Namely (“Mobile App”). When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. In some instances, the use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Namely.

Namely has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements and the TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program covers only information that is collected through this Web site: www.namely.com, the Namely Platform and Mobile App.

TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at info@namely.com. If you are not satisfied with our response you can contact TRUSTe here.

Namely complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Namely has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Namely certification, please visit http://www.export.gov/safeharbor/.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) gathered when you use or access the Services and Mobile App. This Privacy Policy also covers our treatment of any Personal Information that our clients share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (“Third Party Services”) that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

What Information Do We Collect About You?

The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request and collect some of your Personal Information. We collect the following types of information from our users.

Information You Provide Us:

You may choose to provide us with certain Personal Information, such as your name and email address. You acknowledge that by providing this information to us, we may contact you to send you information about the Services.

We do not ask you for, access or track any location based information from your mobile device at any time while downloading or using our Mobile App.

Information Collected Using Cookies:

Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services and Mobile App through the Internet. Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties on the Site. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Information Collected Using Clear Gifs

We and some of our third party partners employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

Information Collected Using Log Files

We and our third party tracking-utility partner use log files to gather certain information automatically. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information, which does not identify individual users, to analyze trends, to administer the site and mobile app, to track users’ movements around the site and mobile app, and to gather demographic information about our user base as a whole.

Social Media Features

Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature 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 are governed by the privacy policy of the company providing it.

Aggregate Information:

We collect statistical information about how both users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you or your web browser.

Information Related to Data Collected for our Clients

Service Provider Collection and Use:

When acting as a service provider, Namely collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes.

Choice

When acting as a service provider, we collect information for our clients, if you interact with one of our Clients and would no longer like to have your Personal Information used by one of our Clients that use our service, please contact the client that you interact with directly.

Access to Personal Information Controlled by our Clients

When acting as a service provider, Namely has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Namely’s Client (the data controller). If the Client requests Namely to remove the data, we will respond to their request within 30 business days.

How, and With Whom, Is My Information Shared?
Third Party Services:

At times, you may be able to access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Site. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Policy only governs information collected on the Services.

Email Communications with Us:

As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to promotions we are offering through the Services. You may opt-out of receiving such communications by following the instructions included with such emails, or emailing us at info@namely.com.

Information Shared with Our Agents:

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control such as an email service provider to send emails on our behalf, mapping service providers, and customer support providers (our “Agents”). We may need to share Personal Information with our Agents in order to provide Services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce these Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Information We Share With Your Consent:

Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information. We will share your Personal Information only in the ways that are described in this Privacy Policy.

Access To Personal Information

If your Personal Information changes, or if you no longer desire our service, you may correct, update, delete/deactivate it by logging into your account and making the appropriate changes or by emailing our customer support at support@namely.com. We will respond to your request to access within 30 days.

We will retain your Personal Information, the Personal Information we process on behalf of our Clients, and geo location data for as long as needed provide services to our Client, for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security

The security of your personal information and our clients’ information is important to us. When you enter sensitive information (such as login credentials and geo location data) we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact info@namely.com.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email prior to the changes becoming effective. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to info@namely.com or via postal mail at 45 West 34th Street, Suite 710-712, New York, NY 10001. We will make every effort to resolve your concerns.

Effective Date: May 6th, 2013