Privileged & Confidential:
Effective Date: November, 2022
This Privacy Policy outlines the information protection practices of EonPath ("EonPath," "we," "us," or "our"). It applies to information we collect and use about you when you access or use EonPath’s website, engage with any of our services (both online and offline), or communicate and interact with us. It also covers any information we may collect from third-party sources to enhance our offerings. Collectively, we refer to our products and services as the “Services.”
Please note that this Privacy Policy does not cover activities EonPath undertakes on behalf of clients under a Services Agreement, where we act as a service provider. For questions regarding such processing or to exercise your rights, please contact the relevant client directly.
PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
This Policy includes the following sections:
1. WHAT INFORMATION WE COLLECT?
We collect information about you from various sources:
Information You Provide to Us
We collect a variety of information that you provide directly to us. For example, we collect information from you through:
- The Services you use
- “Contact Us” submissions or questions and comments you submit to us via online forms, email, or otherwise
- Testimonials you provide
- Requests for customer support and technical assistance
The types of information we may collect directly from you includes:
- Email address
- First and last name
- Login and registration information
- Information about the client or prospective client you are contacting us about
- Information about your support and customer success interactions with us
- Information provided in responses to surveys we conduct
- Information such as your interests and preferences
- Any other information you choose to directly provide to us in connection with your use of the Services
Information We Collect Through Automated Means
When you use our Services, we and our service providers (who are third parties that perform services on our behalf) automatically collect certain information about your device and how you use the Services, including your IP address, browser type, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), number of clicks, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, and other similar information. From your IP address, we may be able to infer your general location (e.g., city/state or postal code).
To collect this information, we and our service providers may use "cookies" or similar tools that track, measure, and analyze the behaviors and usage patterns of our users. Cookies are small information files that can be stored on your browser and device so we can recognize you when you return. We use cookies for analytics purposes, to deliver certain features of the Services, to help us understand how users engage with the Services, and to improve your experience. You may set your web browser to notify you when you receive a cookie and to accept or refuse certain cookies. However, if you elect not to accept cookies, some functionality and areas of the Services may be restricted. For more details, please refer to our Cookie Policy.
Information We Collect from Others
From time to time, we may collect information about you from other sources, including our affiliates, marketing vendors, and third-party databases. We use this information to supplement the information that we collect directly from you and for any of the purposes described in the next section.
As part of our Data Products, we collect a variety of information from partners and public sources, which may include:
- Contact information, such as your name, address, phone number and email address.
- Demographic information, such as general descriptive data associated with the individual.
- We do not knowingly collect information from individuals under 18, but we may receive information about how many children are in your household and their year of birth or age range.
- Commercial Information, we collect information about personal property, as well as products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Location Information. We may infer a location based on your IP address and collect from third parties other geolocation information.
- Education Information, like your level of education and what institutions you may have attended.
- Professional and Employment Related Information, we may also collect information about your employment such as job and title, as well as your income level.
When you "like" or "follow" us on Facebook, LinkedIn, Twitter or other social media sites, we may collect some information from you including your name, email address, and any comments or content you post relevant to us.
2. HOW DO WE USE YOUR INFORMATION?
We use your information for various purposes depending on the types of information we have collected from and about you, including to:
- Provide and maintain our Services.
- Better understand your needs.
- Respond to your inquiries and requests for information, and provide you with more effective and efficient customer service.
- Engage in analysis and research regarding the use of the Services, develop new Services, and improve existing Services.
- Measure the effectiveness of our advertising and deliver relevant advertising to you.
- Suggest Services that may be of interest to you.
- Send you promotional emails containing the information we think you will find interesting.
- Customize our Services according to your online behavior and personal preferences.
- Secure our Services and resolve technical issues being reported.
- Comply with any procedures, laws, and regulations which apply to us.
- Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.
Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.
Aggregated/Anonymized Information. We may aggregate and/or anonymize information collected through the Services so that such information does not identify you as the source of the information. We may use such information to improve the Services, for research and marketing purposes, and may also disclose such information to third parties, including advertisers, promotional partners, customers, and sponsors.
3. ONLINE ANALYTICS AND ADVERTISING
Analytics. We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here . If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture information such as when you open our message or click on any links or banners our email contains. This information allows us to gauge the effectiveness of our communications and marketing campaigns.
Online Advertising. In using the Services, we may allow select third party advertising technology partners to place cookies or other tracking technologies on the browser of your device to collect information about you as discussed above. These third parties may use this information to serve relevant content and advertising to you as you browse the Internet, and access their own cookies or other tracking technologies on your browser to assist in this activity. If you are interested in more information about these online advertising activities, and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out link , the Digital Advertising Alliance's Consumer Opt-Out link , or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. You can also opt out of certain online advertising activities by following the instructions in the "How Do I Exercise My Consumer Privacy Rights and Choices" section below. Please note that if you use these mechanisms, you may still see advertising on our Services or across the Internet, but it will not be tailored to you based on your online behavior over time.
Do Not Track ("DNT"). DNT is a privacy preference that web users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Services through cookies and similar technologies, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. Please note that DNT is a different functionality from the legally-required browser-based global privacy control signal, which EonPath does honor in accordance with applicable legal obligations.
4. WHO DO WE DISCLOSE THIS INFORMATION TO, AND WHY?
Like many businesses, we sometimes have companies perform certain business-related functions for us. These companies include our database service providers, backup and disaster recovery service providers, email service providers, professional advisors, and others. When we engage these companies, we may provide them with your information, including personal information, so they can perform their designated functions. They are not permitted to use your personal information for other purposes than as set forth in our agreement with them.
We may also disclose your information:
- to our affiliates.
- to online analytics and advertising partners to assist us with marketing and advertising.
- as part of corporate restructuring, such as a sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, and the diligence processes in relationship to such restructuring.
- to our clients, in connection with our services
- as required by law or to protect the rights, property or personal safety of EonPath, its agents and affiliates, its users and/or the public.
- 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 disclose personal information.
- Provide you access to and/or a copy of certain personal information we hold about you.
- Correct or update personal information we hold about you.
- Delete certain personal information we have about you.
- Restrict or object to certain uses of your personal information.
5. HOW DO YOU EXERCISE YOUR RIGHTS AND CHOICES?
Email CommunicationsIf you wish to update your email marketing preferences, or unsubscribe, you can do so by clicking the unsubscribe link in the bottom of the email or by emailing us at privacy@eonpath.com. Please note that even if you unsubscribe, we may still send you transaction-related communications.
Your Legal Rights
You can make more specific requests with respect to your personal information depending on where you live. Your local law may permit you to request that we:
Such laws may also permit you to revoke your consent to the processing of your information for certain purposes. We will consider all requests and provide our response within the time-period stated by applicable law and as otherwise required by applicable law. However, certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. Depending on applicable law, you may have the right to appeal our decision to deny your request. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
As provided in applicable law, you also have the right to not be discriminated against for exercising your rights.
If you are a client end user and your information has been collected by EonPath as a result of our Client's use of the Services pursuant to a Service Agreement between Client and EonPath, EonPath collects and processes any information of yours under the directions of the relevant client. If these circumstances apply to you and you wish to access, correct, delete or exercise any rights you may have under applicable information protection laws with respect to any information that we have collected about you, please direct your query to the relevant client, as this may expedite the completion of your request. We will provide reasonable assistance to our client to give effect to information subject rights as appropriate and required by applicable laws.
Notice of right to opt out of sales of personal information and processing/sharing of personal information for targeted advertising purposes
Depending on your jurisdiction, you may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”
As explained in the “Who We Disclose This Information To, and Why” section above, we sometimes disclose information to our clients in connection with our Data Products so that our clients can provide offers that may be of value to you. We also provide information to third-party advertising providers for targeted advertising purposes or use advertising analytics partners to assist us in analyzing use of our services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the “processing/sharing of personal information for targeted advertising purposes.”
If you would like to opt out of the disclosure of your personal information, through cookie and pixel technology, for purposes that could be considered “sales” for those third parties' own commercial purposes, or processing/sharing of personal information for targeted advertising purposes”, please visit the following link, available here. Note that you will need to opt out on each device you use to access the Services. To opt out of our disclosure of your information to our clients and partners in ways that could be considered "sales" or " processing/sharing of personal information for targeted advertising purposes," but where the disclosure is not cookie/pixel-based, please email us at privacy@eonpath.com.
Please note that we do not knowingly sell the personal information of minors under 16 years of age.
6. HOW IS YOUR INFORMATION SAFEGUARDED?
EonPath is committed to securing your information and keeping it confidential. We've taken reasonable precautions to safeguard all the information we collect online to prevent information theft, unauthorized access, and disclosure. However, no Internet or email transmission is ever fully secure or error-free. Please keep this in mind when disclosing any information to us online.
7. LINKS TO OTHER WEBSITES
Our website contains links that lead to other websites. If you click on these links, EonPath is not held responsible for your information and privacy protection. Those websites are not governed by EonPath or this Privacy Policy.
8. HOW LONG IS YOUR INFORMATION RETAINED?
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws.
9. INTERNATIONAL TRANSFERS
Our Services are primarily located in the United States. Your use of the Services may therefore involve the transfer of your information to locations outside of the country where you reside. The level of information protection in countries to which your information is transferred may be less than that offered within the original country. Where this is the case, we will implement appropriate measures to ensure that such information remains adequately protected and secure in accordance with applicable data protection laws.
10. ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. Our use of third-party online advertising services, which are described in detail above, may result in the disclosure of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” or "sharing" under the CCPA.
The following chart details these activities:
7. LINKS TO OTHER WEBSITES
8. HOW LONG IS YOUR INFORMATION RETAINED?
9. INTERNATIONAL TRANSFERS
10. ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
The following chart details these activities:
| Category of Personal Information | Purposes of Use | Categories of Third Parties to Which We Disclose this Personal Information | Categories of Third Parties to Which We “Share” and “Sell” this Personal Information for Advertising/Analytics Purposes |
|---|---|---|---|
| Contact information (such as your full name and email address) | Provide the Services; Communicate with you; Marketing and advertising; Analyze use of and improve the services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Online advertising and analytics partners; Entities for legal purposes | Online advertising and analytics partners. We do not sell. |
| Customer service interaction information | Provide the Services; Communicate with you; Analyze use of and improve the services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Entities for legal purposes | We do not share/sell |
| Surveys and sweepstakes information | Provide the Services; Communicate with you; Marketing and advertising; Analyze use of and improve the services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Entities for legal purposes | We do not share/sell |
| Demographic information (e.g., age range, personal characteristics, information about your household) | Provide the Services; Communicate with you; Marketing and advertising; Analyze use of and improve the services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Online advertising and analytics partners; Entities for legal purposes | Online advertising and analytics partners |
| Commercial information (e.g., information about prior purchases you have made) | Provide the Services; Communicate with you; Marketing and advertising; Analyze use of and improve the services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Online advertising and analytics partners; Entities for legal purposes | Online advertising and analytics partners |
| Internet network and device information (such as mobile device information, IP address, and information about your interaction with the Services) | Provide the Services; Marketing and advertising; Analyze use of and improve the services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Online advertising and analytics partners; Entities for legal purposes | Online advertising and analytics partners |
| Login information (such as your username and password) | Provide the Services; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Entities for legal purposes | We do not share/sell |
| Professional or employment information (such as the name and address of the company you work for and your title) | Provide the Services; Communicate with you; Marketing and advertising; Analyze use of and improve the services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Online advertising and analytics partners; Entities for legal purposes | Online advertising and analytics partners. We do not sell |
| General geolocation data | Provide the Services; Communicate with you; Marketing and advertising; Analyze use of and improve the services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Online advertising and analytics partners; Entities for legal purposes | Online advertising and analytics partners |
| Other information (any other information you choose to provide directly to us) | Provide the Services; Communicate with you; Marketing and advertising; Analyze use of and improve the services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Entities for legal purposes | We do not sell/share |