Effective date: February 14, 2018
Revision date: May 4, 2018
If you are based in Europe for the purposes of European data protection legislation, the controller of your personal information is Periscope, Inc with offices at 1125 Mission Street, San Francisco, CA 94103.
Our nominated representative for the purposes of the European legislation is Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP.
The Personal Information We Collect
Information You Provide to Us:
We receive and store any information you knowingly provide to us. For example, if you tag a page in our repository, we’ll record the keywords that you provided. Also, when you purchase a Service subscription, we will collect payment related information. Certain information may be required to register with us or to take advantage of some of our features. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description. If you do not provide us with such information, your access to or use of the Service may be limited.
Other Information Collected from Your Use of the Service:
Whenever you interact with our Service, we may automatically receive and record information on our server logs from your browser or device, which may include your IP address, device identification, “cookie” information, the type of browser and/or device you’re using to access our Service, and the page or feature you requested. The data that we collect can tell us how often users use a particular feature of the Service, and we can use that knowledge to make the Service better and more useful to as many users as possible. We do not track information about your online activity after you leave our Services.
Information Collected from Third Parties:
We may collect Personal Information from third parties we reasonably believe have the right to provide such information to us (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). In addition, we may collect Personal Information with your consent or as required by law or regulation.
How We Use Personal Information
Periscope uses your Personal Information as follows:
- To operate and maintain the Service (such as, for the purposes of fixing malfunctions, testing our security systems, etc.).
- To provide you with the features, functions and benefits of the Service.
- To processing billing for your Service subscription (i.e. charging your credit card).
- To enhance, improve and further develop the Service (such as, creating new features or functions, refining the user experience, increasing Service technical performance, etc.).
- We will use your contact information to provide you with notices related to your use of the Service.
- Where we have your permission to do so, or where you are an existing customer and we have a legitimate business interest (see below) and have carried out a balancing test to determine that your rights do not outweigh that legitimate interest, we will use your contact information (such as, your email address) to provide you with promotional and marketing emails. You can opt-out of receiving promotional and marketing emails at any time, but if you do you may not receive the full benefit of the Service. Opting-out can be done by following the instructions at the bottom of the promotional material or by contacting us using the information under “Contacting Us” section below.
- To help personalize the Service experience for you (such as, remembering your information so you will not have to enter it each time you use the Service).
- And for the other purposes referenced in the “Who Periscope Shares Your Personal Information With” section below (such as, for the purposes of legal compliance).
We process Personal Information for certain legitimate business purposes, which include some or all of the following:
- where the processing enables us to enhance, modify, personalise or otherwise improve our services’ communications for the benefit of our customers;
- to identify and prevent fraud;
- to enhance the security of our network and information systems;
- to better understand how people interact with our websites;
- to provide postal communications which we think will be of interest to you e.g. information about new products and services; about new initiatives; case studies and whitepapers; to determine the effectiveness of promotional campaigns and advertising.
“Legitimate Interests” means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience.
When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
You can object to our use of your Personal Information for our legitimate interests. See the “Your Rights” section below.
Who Periscope Shares Your Personal Information With
We neither rent nor sell your Personal Information in personally identifiable form to anyone. However, we may share your Personal Information with third parties as described in this section:
With your Consent:
We may share your personal information with third parties with your express consent.
We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing service to charge your Card. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. Details of the Agents we use can be found here https://www.periscopedata.com/privacy-policy/subprocessors
We may choose to buy or sell the assets of Periscope, Inc. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
Protection of Periscope and Others:
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.
U.S. Federal Trade Commission enforcement: Periscope, Inc’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
Aggregated Personal Information that’s no longer personally identifiable:
We may anonymize your Personal Information so that you are not individually identified, and provide that information to our partners. We may also provide aggregate usage information to our partners, who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate information to any third party in a manner that would identify you personally, as an individual.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to [email protected].
How Long We Keep Your Information For
We will retain personal information for as long as it is needed for legitimate business purposes to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We keep such servers to help protect the stability and availability of the Service (such as protecting it from viruses and malfunctions).
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal information are available in our retention policy which you can request from us by contacting us. See the “Contacting Us” section below.
What You can do to Your Personal Information
Deleting your account:
You can delete your account by emailing [email protected]. Subject to the “Limitations on Deletion” section below, when you request for us to delete your account for the Service, your data will be permanently deleted from our servers and access to your account will be disabled.
We may retain your Personal Information in accordance with our retention policy (see the “How Long We Keep Your Information For” section) and to the extent required to comply with (or we deem it reasonable in light of) any laws or regulations.
For those in the European Union, the United Kingdom or Switzerland:
If you are based in the European Union you can also do the following:
Ask us to stop contacting you with direct marketing.
Even if you have accepted the processing of your personal information for marketing purposes (by ticking the relevant box), you have the right to ask us to stop processing your personal information for such purposes. Let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
Requesting a copy of your information.
You can request a copy of your information which we hold (in Europe this is known as a subject access request). If you would like a copy of some or all of it, please contact us and let us know the information you want a copy of, including any account or reference numbers, if you have them. Any subject access request may be subject to a reasonable fee to cover the cost of providing you with details of the information we hold about you.
Correcting any mistakes in your information.
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please contact us and let us know the information that is incorrect and the information you want it replaced with.
Request us to cease processing your information.
You may request that we cease processing your personal information. If you make such a request, we shall retain only the amount of personal information pertaining you that is necessary to ensure that no further processing of your personal information takes place.
Data Portability Request
You have rights to obtain a copy of some of the Personal Information that we hold on you and reuse or share it for your own purposes (“right to data portability”).
The right to data portability only applies:
- to Personal Information you’ve provided to us (i.e. not any other information),
- where we are processing your Personal Information because you have provided your consent for us to do so, or under a contract with you; and
- when processing is carried out by automated means.
We can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the Personal Information concerns more than one individual, we may not be able to transfer the information to you if doing so would prejudice the other person’s rights.
The Location of Your Personal Information
While your Personal Information is in our possession, it will be primarily stored at hosting facilities located in the USA. These facilities are either operated by Periscope or our third party providers. By using the Service you are consenting to have your Personal Information stored, transferred and processed in the USA.
Additional Information for those based in the European Union:
Whenever we transfer your personal information out of the European Union, we ensure a similar degree of protection is afforded to it by ensuring that the organisation to which it is transferred is E.U.-U.S. Privacy Shield Framework certified or alternatively that at least one of the other safeguards listed below is implemented.
To learn more about the Privacy Shield program, and to view our certification (where you will find details of what information is sent to Periscope, Inc, and the purposes for which it processes it), please visit https://www.privacyshield.gov/.
If you have a concern about the way your data has been handled when it was collected by Periscope, Inc in the United States using the Privacy Shield Framework, please refer to the “Complaints” and “Dispute Resolution” sections below.
Adequacy: the transfer is made only to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission webpage on Adequacy: https://ec.europa.eu/info/law/law-topic/data-protection_en, or
EU Model Contracts/Standard Contractual Clauses: where the party is outside of the European Union, not in a country subject to an adequacy decision and not privacy shield certified, we enter into specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission webpage on Model Contract Clauses: https://ec.europa.eu/info/law/law-topic/data-protection_en
The Security of Your Personal Information
Periscope takes certain precautions to protect your Personal Information and to limit the risk that it will be accessed without authorization, including use of certain industry standard technologies and practices. That said, we cannot guarantee the security of such information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. No security system is perfect, so your use of the Service is at your own risk.
In addition to the security measures referenced above, your Service account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
Information from Children
We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Service or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at [email protected].
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
For residual complaints not fully or partially resolved by other means, you may be able to invoke a binding arbitration mechanism.
If you have any questions or concerns regarding our privacy policies, please send us a detailed message at [email protected], or: 1125 Mission Street, San Francisco, CA 94103.
Links to Other Websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over other websites and their content. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.