Date of Last Revision: 2020-02-07
You should read this policy in full, but here are a few key takeaways:
- Attach is public and your comments are immediately viewable and searchable by others. You can use Attach under a pseudonym if you prefer not to use your name, but keep in mind that nobody is anonymous on the internet.
- When you use Attach, even if you're just looking at comments or feeds, we receive some personal information from you like the languages you possibly speak and your IP address.
- You can choose to share additional information with us like your email address and a public profile. We use this information for things like informing you better, keeping your account secure, and showing you more relevant stuff.
- We collect the absolute minimum of personal information necessary, and under no circumstances will we share such information with advertising companies. If we display ads to you, these are exclusively based on your current browser session, the languages you speak, and your search.
- You can always download, modify, correct or delete the personal information we have stored in your profile, but we may not be able to delete certain types of information, such as comments, messages or videos. We will try to anonymize such information, but rather be careful what you post or share.
If you have questions about this policy, how we collect or process your personal data, or anything else related to our privacy practices, feel free to contact us at [email protected]
Unless otherwise indicated, capitalized terms used in this Policy are defined in our Terms.
We keep your personal information personal and private. We do not sell, rent, share, or otherwise disclose your personal information to anyone except as necessary to provide our Services or as otherwise described in this Policy.
This Policy applies to Attach's collection, use, and disclosure of the information of the following categories of individuals:
Attendees Individuals who provide their information to Attach or Attach representatives when they attend or register to attend Attach-sponsored events or other events at which Attach participates.
Site Visitors Individuals who visit our Site who may opt to provide an email address to receive communications from Attach. As specified in our Terms, for the purpose of this Policy, "Site" shall collectively refer to websites and mobile applications Attach owns and that link to this Policy. For clarity, "Site" does not include any sites owned or operated by our Customers, including where we provide Attach Services.
Customers Those who register on their own or on behalf of an entity or organization to use any of the Attach Services, including administrators and developers on a Customer account. For the purposes of this Policy, "Services" shall refer to all services, provided for free or marketed for subscription at https://developers.attach.live, including when Services are sold by an authorized partner or reseller.
End Users Individuals who visit our Customers' websites and whose information we process in order to provide the Services to our Customers pursuant to our agreements with them. This Policy does not apply to our Customers' websites, which may have their own terms and privacy policies. Our Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, including those relating to the collection of personal information in connection with the use of our Services by End Users with whom our Customers interact.
Attach's Site and Services are not intended for, nor designed to attract, is not intended for use by children under the age of 13. We do not knowingly collect personal information from children under 13 or knowingly allow such persons to register for an account. In the event that we learn that we have collected personal information from a child under the age of 13, we will delete it. If you believe that we might have collected personal information from a child under 13, please contact us at [email protected]
Advertisers Those who register on their own or on behalf of an entity or organization to advertise with Attach, including administrators on an Advertiser account.
Attendees We may ask for and collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which Attach (and/or its representatives) participates.
Name, Email Address, and Other Contact Information. We ask for and —at your option— collect personal information from you when you submit web forms on our Site, including opportunities to sign up for and agree to receive email communications from us. We also may ask you to submit such personal information if you choose to use interactive features of the Site, including participation in surveys, contests, promotions, sweepstakes, requesting customer support, or otherwise communicating with us. We will send such communications in accordance with applicable law.
You don't have to create an account to use some of our Site and Services, such as viewing feeds, comments, videos, or searching. If you do choose to create an account, you must provide us with some personal information so that we can provide our services to you. The minimum information we collect during sign-up is your email address, a username, avatar image, and password. Where provided, you can also create an account by instructing another social media provider like Twitter or Facebook to sign you in with Attach, in which case we receive all or part of your personal information directly from the provider.
Log data. Just as when you visit and interact with most websites and services delivered via the Internet, when you visit our Site or use our Services (even if you do not have an account with us), we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, your mobile carrier, URLs of referring pages, and locale and language preferences.
We permanently delete log data after 30 days. Except where explicitly stated, we do not use Log Data to improve the content we display to you, including ads. We also do not collect and associate Log Data with your account and we only store Log Data which is absolutely necessary to prevent spam, abuse, and other illegal activities on our developers platform, or where we are legally required to do so.
Interactive Areas. The Site or Attach embeds on our Customers' websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features ("Interactive Areas"). If you choose to participate in any of these Interactive Areas, please be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. If you wish to remove your personal information from any of our Interactive Areas, see Section 7 below for data subject rights.
Location Information. We collect from your browser the languages you may speak and locales (the countries or regions where these languages are spoken). We may aggregate Location Information into your account so we can provide better service to you and others. If we associate Location Information with your account, we always anonymize your IP address and we never store your exact location such as your geolocation coordinates or your street address.
Links. We do not systematically follow you and we don't keep track of the links you click, but if you click on an external link or ad on our services, that website operator or advertiser might figure out that you came from Attach, along with other information associated with the ad you clicked, such as characteristics of the audience it was intended to reach. They may also collect other personal data from you.
Customer Account Information. When you register for an Attach account, we collect your email address. We will also ask you to enter your website domain and other information about the company and its representative in order to participate in the Services. We refer to this information as "Customer Account Information" for the purposes of this Policy. Customer Account Information is required to identify you as a Customer and permit you to access your account(s). By voluntarily providing us with such Customer Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
Payment Information. You are not required to enter your credit card information unless and until you decide to use one of our paid Services. When you sign up for one of our paid Services, you must provide billing information. The information you will need to submit depends on which billing method you choose. For example, if you pay with a credit card, we will collect your card information and billing address. We do not store full credit card numbers or personal account numbers.
End Users Attach provides social media services that our Customers use on their websites. It is our Customers and their users who are responsible for the content transmitted across our network. We collect End Users' information when they use our Customers' websites, web applications, and APIs. This information may include but is not limited to IP addresses, system configuration information, and other information about traffic to and from Customers' websites (collectively, "Log Data"). We collect and use Log Data to operate, maintain, and improve our Services in performance of our obligations under our Customer agreements. For example, Log Data can help us to detect new threats, identify malicious third parties, and provide more robust security protection for our Customers.
Advertiser Account Information. When you register for an Attach account, we collect your email address. We will also ask you to enter your website domain and other information about the company and its representative in order to advertise with Attach. We refer to this information as "Advertiser Account Information" for the purposes of this Policy. Advertiser Account Information is required to identify you as an Advertiser and permit you to access your account(s). By voluntarily providing us with such Advertiser Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
Payment Information. You are required to enter your credit card information if you wish to advertise with Attach. The information you will need to submit depends on which billing method you choose. For example, if you pay with a credit card, we will collect your card information and billing address. We do not store full credit card numbers or personal account numbers.
Legal Basis for Processing (European Economic Area only):
If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally will collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you (e.g. to deliver the Attach Services you have requested), or (c) where the processing is in our legitimate interests. Please note that in most cases, if you do not provide the requested information, Attach will not be able to provide the requested service to you.
In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal data, you have the right to object.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at [email protected]
Attach only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. As a general matter, for all categories of data we collect we may use the information we collect (including personal information, to the extent applicable) to:
- provide, operate, maintain, improve, and promote the Site and Services;
- enable you to access and use the Site and Services;
- process and complete transactions, and send you related information, including purchase confirmations and invoices;
- send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
- send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners (see Section 8 below for information on managing your communication preferences);
- process and deliver contest or sweepstakes entries and rewards;
- monitor and analyze trends, usage, and activities in connection with the Site and Services and for marketing or advertising purposes;
- comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Site and Services, and other illegal activities;
- personalize the Site and Services, including by providing features or content that match your interests and preferences; and
- process for other purposes for which we obtain your consent.
We use your email address and password to authenticate your account and keep it secure. We encrypt your personal information while it is stored in our databases and during transit. Because Attach uses one-way encryption when storing your password, it cannot be read anymore, not even by us. If you forget your password, you may lose your account.
While we will never share your email address and password with others, you may decide to voluntarily share additional profile information publicly or with us. If we make profile information available for public sharing, we will clearly label each piece of information so you know exactly what is shared. If you give us additional profile information but do not share it with others, we may use it for providing a better service to you.
We use your email to send you information about our Site and Services. If you are using one of our mobile apps or accept notifications in your web browser, we may send you notifications as well. You can use your profile settings to control which categories of emails and notifications you wish to receive from Attach.
If you email us or request support, we will keep the content of your messages, your email address, and your contact information to respond to your request.
Think carefully about what you publish or share, especially if it is sensitive information. You are responsible for your comments, videos, feeds, and other information you provide through our Services.
We publicly share your username, avatar image, and the languages you possibly speak. We also share comments, videos, and feeds that you post, and associate them with information of what, when and where you posted. We associate your votes and replies with the related content and may share your actions publicly. Actions by others may become public as well, such as when these reply to you, tag you or share with you publicly.
In addition to sharing your public information and what you post, we also use technology like application programming interfaces (APIs) and embeds to make that information available to websites, apps, and others for their use. For example, others may display your comments or videos on their website, even though these individuals and companies are not affiliated with Attach.
Attach will never collect data from your address book or send email invites to your friends. If you would like to see your friends on Attach, share with them directly or invite them personally to sign up.
Attach does not currently offer Direct Messages or other private communication.
Information from Third Party Services. We may combine information we collect as described above with personal information we obtain from third parties. For example, we may combine information entered on an Attach sales submission form with information we receive from a third-party sales intelligence platform vendor to enhance our ability to market our Services to Customers or potential Customers.
Specifically, we do not permit our Service Providers to use any personal information we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us.
In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:
- within the Attach Group;
- with our resellers and other sales partners who may help us distribute the Services to Customers;
- with a Customer whose website or app uses the Attach Services;
- in the event of a merger, sale, change in control, or reorganization of all or part of our business;
- when we are required to disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
- where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required to comply with our legal obligations; or
- as you may otherwise consent from time to time.
We do not sell, rent, or share personal information with third parties for their direct marketing purposes, including as defined under California Civil Code Sec. 1798.83 and the EEA General Data Protection Regulation (GDPR) (EU) 2016/679.
Attach may aggregate data we acquire about our Customers and their End Users, including the Log Data described above. For example, we may assemble data to compile web traffic reports and statistics. We may share non-personally identifiable, aggregated data with third parties. We always anonymize data we aggregate, so it cannot be traced back to you or your account.
Attach is a U.S.-based, global company. We primarily store your information in the United States and the European Economic Area (the "EEA"). To facilitate our global operations, we may transfer and access such information from around the world, including from other countries in which the Attach Group has operations for the purposes described in this Policy.
Whenever Attach shares personal information originating in the EEA or Switzerland, with an Attach entity outside the EEA or Switzerland, it will do so on the basis of the EU standard contractual clauses or the Privacy Shield Frameworks detailed in this section.
If you are accessing or using our Site or Services or otherwise providing information to us, you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate.
Attendees, Site Visitors, and Customers You have the right to access, correct, update, export, or delete your personal information. You may email us at [email protected] with any such subject access requests ("SAR"), and we will respond within thirty (30) days. Customers also can access, correct, export, or update their Account Information by editing their profile or organization record at https://developers.attach.live.
End Users Attach has no direct relationship with End Users. Accordingly, we rely upon our Customers to comply with the underlying legal requirements for subject access requests. If an End User requests that we access, correct, update, or delete their information, or no longer wishes to be contacted by one of our Customers that use our Services, we will direct that End User to contact the Customer website(s) with which they interacted directly. Our Customers are solely responsible for ensuring compliance with all applicable laws and regulations with respect to their website users.
For any SAR, we will need to verify a requestor is inquiring about their own information before we can assist. Where a SAR may implicate the personal data of another individual, we must balance the request against the risk of violating another person's privacy rights. We will comply with SARs to the extent required by applicable law, the GDPR, or the US-Swiss or US-EU Privacy Shield. In the EU, you also have the right to lodge a complaint with the supervisory authority in your country.
You may manage your receipt of commercial communications by clicking on the "unsubscribe" link located on the bottom of such emails, through your account settings if you have an account with us, or you may send a request to [email protected]
We take all reasonable steps to protect information we receive from you from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We have put in place appropriate physical, technical, and administrative measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as encryption. If you have any questions about the security of your personal information, you can contact us at [email protected]
If we make changes to this Policy that we believe materially impact the privacy of your personal data, we will promptly provide notice of any such changes (and, where necessary, obtain consent), as well as post the updated Policy on this Site noting the effective date of any changes.
We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganization of all or part of our business.
Non-English translations of this Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.
Closeup, Inc. Attention: Data Protection Officer BM-286451 8400 NW 25th Street Suite 100 Doral, FL 33198-1534 United States