Namely is responsible for the processing Personal Information it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Namely complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU and Switzerland, including the onward transfer liability provisions.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, Namely is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we 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 you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
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.
You may choose to provide us with certain Personal Information, such as your name, email address and phone number. We collect sensitive information such as ethnic origin of the individual for the purpose of collecting ethnographic data as an aggregate. 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. We may request access to your device’s camera and photo storage. This allows you to take and upload pictures and such access would only be used in ways you choose. You may at any time revoke access at the device level. We do not access your device’s camera and photo storage without your permission. We use mobile analytics software to allow us to better understand the functionality of our Mobile App on your phone. This software may record information such as how often you use the application, the events that occur within the application, 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 submit within the Mobile App. When you download and use our Services, we automatically collect your device information such as operating system version, type, hardware usage statistics, etc.
We partner with a third party to either display advertising on our Site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this Site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not 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 this does not opt you out of being served ads. You will continue to receive generic ads.
You can log in to our Site using sign-in services such as Log in With Google or an Open ID provider. These services will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our sign up form.
Our Site offers publicly accessible blogs or community forums. You should 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 from our blog or community forum, contact us at email@example.com. 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.
We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
If you choose to use our referral service to tell a friend about our Site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Site. Namely stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us at email@example.com to request that we remove this information from our database. If you believe that one of your contacts has provided us with your Personal Information and you would like to request that it be removed from our database, please contact us at firstname.lastname@example.org.
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.
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 Information it processes.
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.
When acting as a service provider, Namely has no direct relationship with the individuals whose Personal Information it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data or no longer want to be contacted by one of our Clients should direct his query to the Namely Client (the data controller). If the Client requests Namely to remove the data, we will respond to their request within 30 business days.
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 email@example.com.
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. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients. You hereby consent to our sharing of Personal Information with our Agents.
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. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. To request this information please contact us at firstname.lastname@example.org.
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 email@example.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 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.
The security of your Personal Information and our Clients’ information is important to us. When you enter sensitive information (such as login credentials) 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 Site, you can contact firstname.lastname@example.org.
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to email@example.com or via postal mail at 195 Broadway, 15th Floor, New York, NY 10007. We will make every effort to resolve your concerns.
Effective Date: June 23, 2017