SmartOrg Privacy Notice

Last Updated: February 16, 2021

SmartOrg, Inc. and its affiliates and subsidiaries (“SmartOrg” or “we” or “our”) respect your privacy. This Privacy Notice describes our privacy practices regarding the collection, use, and disclosure of your information through our website (https://smartorg.com/), SmartOrg’s product Portfolio Navigator^® (“PN”), and our services (“SmartOrg Services”). We provide access to our Privacy Notice by:

(i) linking to it on our website from our privacy policy summary in PN,

(ii) providing links on our public website, and

(iii) incorporating it into our contracts, agreements, and other documents as necessary or appropriate.

1. INFORMATION COLLECTION
Personal Information We May Collect
Other Information We May Collect

2. INFORMATION USE AND DISCLOSURE
How We May Use and Disclose Personal Information
Product Updating and Reporting

3.THIRD-PARTY SERVICES

4.CROSS-BORDER DATA TRANSFERS

5.SECURITY

6.CHILDREN

7.HOW YOU CAN MANAGE YOUR PERSONAL INFORMATION

8.RETENTION PERIOD

9.CONTACT US

10.UPDATES TO THIS PRIVACY NOTICE

INFORMATION COLLECTION

Personal Information We May Collect

“Personal Information” is any information that relates to an identified or identifiable individual. SmartOrg may collect various types of personal information, including:

Personal and business contact information (such as full name, title, phone number, email address, organization, password)
Depending on the service we are providing to you, we may also need to collect more sensitive personal information (such as photographs, audio/video recordings, images) directly from you. These will primarily be used to create training modules for the work that we need to support.

If you submit any personal information about other people to us or to our authorized service providers, you represent that you have the authority to do so and to permit us to use their personal information in accordance with this Privacy Notice.

We and our authorized service providers may collect personal information from a variety of sources, including:

From you or someone acting on your behalf: We may collect personal information you or someone acting on your behalf shares with us such as your name and contact details.

Through SmartOrg Services: We may collect personal information about you when you use PN, sign up using any of our website forms or subscribe to any content . For example, when you sign up for our newsletter ValuePoint™ or use PN.

Through Third Parties’ Services: We do not pass on your personal information to any third-party services.

Other Information We May Collect

SmartOrg may also collect other information from your app, browser, or device that does not reveal your (or anyone else’s) real world identity, for example:

Browser and device information
App or device usage data
Information collected through cookies, pixel tags, and similar technologies
IP address
Location data
Aggregated, anonymized, or de-identified information
Demographic information and other information provided by you (i.e., language, occupation, postal code).

We and our authorized third-party service providers may collect this information in a variety of ways, including:

Through your browser or device: Most browsers and devices collect certain information automatically, for example, type and version of operating system, screen resolution, device manufacturer and model, language, Internet browser type and version, and the name and version of the application (of PN) that you are using. We use this information, for example, to make sure that the SmartOrg Services function properly, analyze the performance of our products, and improve and maintain the SmartOrg Services.

Through cookies and similar technologies: We use cookies to store PN’s authentication information, help create short links to reports, and help PN work more efficiently.

IP Address: IP addresses are automatically transmitted as part of any Internet communication, and collecting IP addresses is a common practice; many websites, applications and PN collect IP addresses automatically. We use IP addresses for purposes such as communicating with your device, calculating usage levels of PN, helping diagnose server problems, security, and administering the SmartOrg Services.

INFORMATION USE AND DISCLOSURE

How We May Use and Disclose Personal Information

We may use personal information:

To provide SmartOrg Services.
To respond to your inquiries and fulfill your requests, such as to send you technical documents or white papers.
To allow you to send messages to other users in the same PN deployment for your organization.
For our business purposes, such as data analysis, audits, crime/fraud monitoring and prevention, security, developing new products, testing, enhancing, improving or modifying our SmartOrg Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
Perform accounting, auditing, billing, reconciliation, and collection activities.
For promotions (paid and organic), email, surveys, or other marketing on topics relevant to SmartOrg’s thought leadership by us, our vendors or affiliates, for example, announcing an upcoming conference or course.
To send administrative information and service notifications to you, for example, information regarding the SmartOrg Services and changes to our terms, conditions, and policies.
Perform other activities consistent with this Notice.

Personal information may be shared or disclosed:

To our affiliate entities and subsidiaries for the purposes described in this Privacy Notice.
To our authorized service providers and suppliers who provide services to us such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services.
To identify you to anyone to whom you send messages through the SmartOrg Services (including PN).
To a third party in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
As we believe is required, necessary, or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process and/or to respond to requests from competent public and government authorities including public and government authorities outside your country of residence; (c) to enforce our terms and conditions; (d) to protect our operations and those of any of our affiliates; (e) to protect our rights, privacy, security, safety, and physical and intellectual property, and/or the rights of our affiliates, you, or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.

Product Updating and Reporting

Our products and services may also process certain data to provide software updates and reports. These update functions may automatically check your system to see whether files relating to the services need to be refreshed, updated, or modernized.

SmartOrg may also use the information to adapt the product to conform to user preferences based on actual use.

Browser and device information
App or device usage data
Information collected through cookies, pixel tags, and similar technologies
IP address
Location data
Aggregated, anonymized, or de-identified information
Demographic information and other information provided by you (i.e., language, occupation, postal code).

We and our authorized third-party service providers may collect this information in a variety of ways, including:

Through your browser or device: Most browsers and devices collect certain information automatically, for example, type and version of operating system, screen resolution, device manufacturer and model, language, Internet browser type and version, and the name and version of the application (of PN) that you are using. We use this information, for example, to make sure that the SmartOrg Services function properly, analyze the performance of our products, and improve and maintain the SmartOrg Services.

Through cookies and similar technologies: We use cookies to store PN’s authentication information, help create short links to reports, and help PN work more efficiently.

IP Address: IP addresses are automatically transmitted as part of any Internet communication, and collecting IP addresses is a common practice; many websites, applications and PN collect IP addresses automatically. We use IP addresses for purposes such as communicating with your device, calculating usage levels of PN, helping diagnose server problems, security, and administering the SmartOrg Services.

THIRD-PARTY SERVICES

This Privacy Notice does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not SmartOrg service providers, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure. This includes: (a) any third party operating any site or service to which the SmartOrg Services (including PN) link – the inclusion of a link on the SmartOrg Services does not imply endorsement of the linked site or service by us or by our affiliates; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer (such as Facebook, Apple, Google, Microsoft, LinkedIn, etc.) – including any personal information you disclose to other organizations through or in connection with the SmartOrg Services or our Social Media Pages.

When we share personal information with a SmartOrg service provider, we require that they first contractually agree to comply with reasonable and appropriate privacy and security standards.

CROSS-BORDER DATA TRANSFERS

Your personal information may be transferred to, and processed in, countries other than the country in which you are a resident. When you use our website, or our products and services, your personal information processed by SmartOrg may be transferred to the United States, where our business operations are located, and possibly to other countries where our service providers operate. We only collect and/or share your personal information to the extent it is necessary to conduct business and perform requested services. We employ appropriate safeguards for cross-border transfers of personal data, as required by applicable local law.

SECURITY

The SmartOrg Services are designed to provide reasonable and appropriate organizational, technical, and administrative measures to protect personal information within our organization against unauthorized or unlawful access, alteration, disclosure, or destruction. Users of SmartOrg Services must also do their part in protecting the data, systems, networks, and service they are utilizing. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that your password to any SmartOrg account has been compromised), please immediately notify us by contacting us in accordance with the “Contact Us” section below.

CHILDREN

We do not direct our website to minors, and we do not knowingly collect personal information from children under 16 or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal information from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at privacy@smartorg.com.

HOW YOU CAN MANAGE YOUR PERSONAL INFORMATION

If you would like to correct, update, delete, or request access to the personal information that you have provided to us, you may directly do so through PN’s Address Book or contact us at privacy@smartorg.com.

Email and Marketing

We give you choices with respect to marketing materials. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located at the bottom of marketing emails, or checking certain boxes found on forms we use to collect personal information.

Storage of the information we collect from you

The information we collect may be stored and processed in servers in the United States and wherever SmartOrg and our service providers have facilities around the globe and in accordance with local laws.

RETENTION PERIOD

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. We may delete the accounts of inactive users if they have been inactive over one (1) year. We also allow customers’ system administrators to remove users they deem as not needing access.

CONTACT US

If you have questions or concerns about SmartOrg’s privacy practices, you can contact us by using the Contact Us link or send a letter to the postal address listed below. Please include your contact information, name of the SmartOrg Service or website, and a detailed description of your request or privacy concern.

SmartOrg, Inc. ATTN: Privacy Office
99 Almaden Boulevard, Suite 975
San Jose, CA 95113

UPDATES TO THIS PRIVACY NOTICE

We may change this Privacy Notice. The “Last Updated” section at the top of this page states when this Privacy Notice was last revised. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on our website and the SmartOrg Services. Your use of our website and the SmartOrg Services following these changes means that you accept the revised Privacy Notice.

If any change may materially and negatively affect the privacy of your personal information, we will use reasonable efforts to notify you in advance and give you a reasonable period of time to object to any changes.

We encourage you to periodically review this Privacy Notice to stay informed about how we collect, use, and share personal information.