Engageion Privacy Policy

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This Privacy Notice covers the processing of personal data and applies to all the products, services, websites and apps (the “Services”) offered by of Engageion Technologies, LLC (the “Company”).
 

Who We Are 

Engageion Technologies, LLC is a Virginia limited liability company and our global Headquarters are located at 11109 Elmview Pl, Great Falls, VA 22066; e-mail: info@enageion.com. 

If you have any questions about how the Company processes personal data, please contact info@enageion.com.  The Company serves as the controller of the information submitted to it or collected in connection with its Services and the means through which the information is processed. 
 

Legal Basis 

The Company will collect and process personal information when an individual or business has consented; when the Company needs to fulfill a contractual responsibility; when the Company has a legitimate interest; and when the Company has a legal obligation.
 

Purpose 

The Company may collect and use personal information of a business or consumer that holds an account related to the Services for purposes reasonably required for day-to-day operations, such as accounting, collecting payments due and owing to the Company, financial reporting, business analytics, operational and strategic business planning, real-estate management, and expense management. The Company may use personal information to comply with local, state, and federal laws; enforce the Company’s legal rights and obligations; and for any purpose in connection with legal claims, reports of violations, or allegations made by, against, or otherwise involving, and to the otherwise comply with lawful requests by public authorities, e-discovery requests or where otherwise required or permitted by applicable laws, court orders, government regulations, or regulatory authorities to assess and understand user interests and preferences (e.g., inferences and derived data). The Company may also use personal information to provide personalized recommendations, marketing, and content; display the Services in a tailored way; and provide personalized marketing and other communications.

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The Company may also collect and use personal information of individuals that receive a survey, form, application, or questionnaire powered by the Services; or a visitor to its website, to perform the Services. The Company may share or make available personal information (such as identifiers, Internet or similar network activity, commercial information, inferences) with third parties (including marketing and advertising networks and social media platforms), including by using cookies (and similar technologies), to serve tailored and personalized advertisements.

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The Company may use personal information collected to understand how the Services are used, and to validate metrics to inform and improve our products, services, websites and apps.  The Company collect and use personal information publicly available, including information publicly posted on social media platforms to better understand how consumers view the Company’s Services and interact with the Company.

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Categories of Personal Data 

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a. The Company may collect contact information (for example: name or email address), whether through use of the Services or in a response to one of the Company’s own surveys or forms. For billing purposes, the Company may require a name, address, email address and financial information corresponding to the selected method of payment (e.g., a credit card number and expiration date or a bank account number). The Company will use the billing address to determine any sales tax, if applicable, to be applied to any purchase.

b. The Company may use first party and third party cookies and tracking services that employ cookies and page tags (also known as web beacons) to collect data about visitors to its websites. This data includes usage and user statistics. Emails sent by the Company or by users through the Services may also include page tags that allow the sender to collect information about who opened those emails and clicked on links in them.

c. The Company may collect usage information about users that have interacted with the Services. This includes which webpages were visited or clicked on, when and what actions were performed, and what Services were purchased and utilized.

d. The Company may collect information from the device and application that are used to access the Services. Device data potentially includes IP address, operating system version, device type, device ID/MAC address, system and performance information, browser type, and other device, network and browser signals. The Company may infer geographic location based on IP address.

e. The Company may keep log files that record data each time a device accesses Company servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed and accessed (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.

f. The Company may record information about any external source that referred a user to the Company.

g. The Company may store survey/form/application data (questions and responses) and provide analysis tools for users to use with respect to this data.
 

Recipients of Your Data 

The Company may share personal data with vendors to perform the Services, who process personal data on the Company’s behalf and follow a strict mandate (they act as processors). 

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The Company may transfer and disclose information, including personal information, to third parties to comply with a legal and compliance obligation; when the Company believes in good faith that the law requires it; or at the request of governmental authorities conducting an investigation. 

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The Company may disclose personal information where it believes doing so is necessary to protect the Services, the Company’s rights and property, or the rights, property, and safety of others.  The Company may disclose personal information to prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services; and/or related to litigation and other legal claims or proceedings in which the Company is involved, as well as for the Company’s internal accounting, auditing, compliance, recordkeeping, and legal functions.

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The Company does not ‘sell’ personal information about its users in exchange for money.  However, the Company may share personal information with third parties to provide users with personalized advertising from the Company, or it may make available personal information to third parties (including due to the use of cookies (or similar technologies) provided by third parties on the Company’s website). In California, this type of activity may be considered (1) a ‘sale’, (2) a ‘share’ of personal information for cross-contextual behavioral advertising, or (3) both, and subject to a right of opt-out. 

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Retention Period 

According to the Company’s retention policy, records containing personal data are kept long as they are necessary for the purposes they have been collected and processed for. The Company is under no obligation to store such personal information indefinitely and disclaims any liability arising out of, or related to, the destruction of such personal information. Users should be aware that it is not always possible to completely remove or delete all personal information from the Company’s databases without some residual data because of backups and other reasons.

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Notwithstanding the foregoing, the Company may also retain personal information about users for as long as their account is active, as needed to provide the Services, and as necessary to comply with any legal and/or regulatory obligations, to resolve disputes, to manage the Company’s rights, and to enforce the Company’s agreements. 

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International Transfers 

If you are located outside of the United States, the Company transfers personal data related to applications and administration of the examination or assessment to the United States. The United States has not sought nor obtained adequacy status for ensuring an equivalent level of protection of personal data, from the European Commission. There are risks associated to the transfers, but the Company has put safeguards in place to protect your data after it is transferred. 

 

To ensure the lawful transfers of personal data from the European Economic Area (EEA), the Company relies on necessity for the performance of a contract as a derogation that allows international transfers to occur (Article 49 GDPR). 

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Your Rights 

The Company is committed to facilitate the exercise of privacy rights granted by data protection laws in a timely manner – the right to access a user’s own data, to ask for erasure, correction, restriction, portability of that data, or to object to the processing of that data. 

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In order to be able to reply to any request and if the Company is not certain of a requestor’s identity, the Company may need to ask for further identification data to be used only for the purposes of replying to that request. If any user has any inquiries or requests, write to [add email address] or contact the Company at the postal address above. 

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Access, Correction, and Other Requests 

Users have the right to obtain confirmation whether the Company processes or not a user’s own personal data, as well as the right to obtain information about the personal data the Company processes about that user and to obtain a copy of this data. 

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A user has the right to obtain erasure, correction (updating or completing the user’s own personal data), restriction, and portability of that user’s own personal data, under certain conditions. 

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Right to object 

A user also has the right to object at any time to receiving marketing materials from the Company by following the opt-out instructions in the Company’s commercial emails, as well as the right to object to the processing of the user’s own personal data based on the user’s specific situation (only in those cases where the Company processes the data on the basis of its legitimate interest, as detailed above). In the latter case, the Company will assess a user’s request and provide a reply in a timely manner, according to any legal obligations. 

For all the processing operations that are based on user consent, as described above, a user can withdraw consent at any time and the Company will stop those processing operations. 

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California Privacy Rights 

California Civil Code Section §1798.83 allows California residents to ask organizations with whom they have an established business relationship to provide certain information about the organizations’ sharing of personal information with third parties for direct marketing purposes. The Company does not share any California consumer personal information with third parties for marketing purposes without consent. California residents who wish to request further information about the Company’s compliance with this law or have questions or concerns about its privacy practices may contact the Company using the contact information provided above. 

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Concerns 

If a user has any concerns or questions about how their personal data is used, please contact our info@engageion.com. 
 

If a user is located in the European Economic Area and believes the Company has not been able to deal with their concern, the user has a right to raise this issue with that user’s local data protection authority. That user has the right to submit a complaint in the Member State of their residence or place of work of an alleged infringement of the General Data Protection Regulation (GDPR). 

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