Privacy Policy

Updated May 23, 2018

Convercent and our affiliates (“Convercent”, “we”, “us” and “our”) respect your privacy, we have developed this Privacy Policy to inform you about our privacy practices for the entire www.convercent.com site (the “Site”), the related applications, services, and platform offered by Convercent (the “Ethics Cloud Platform”) (collectively, the “Services”), and about special privacy practices related to our Privacy Shield Participation. This Privacy Policy describes the types of personal information we collect, how we use the information, with whom we share it, how we secure it and the choices you can make about our use of the information.

Please read the Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.  Please pay particular attention to the sections entitled “International Transfer” and “Your Rights When Convercent is Your Data Controller.”

How does Convercent and its Ethics Cloud Platform Operate? Convercent has entered into separate agreements with our clients to govern the delivery, access, and use of the Convercent Ethics Cloud Platform, including instructions for the processing of personal data on behalf of our clients. Our clients license Convercent technology and configure their instance of the Convercent Ethics Cloud Platform to enable their employees, contractors, customers, and other third parties (collectively “End Users”) to report ethics and compliance issues, file disclosures, receive and take educational courses, attest to corporate policies, and monitor third party vendors.

What Role Does Convercent Serve in Data Protection? It is important to note that Convercent acts both as a Data Controller and a Data Processor within the realm of data protection law compliance (including the GDPR). As a Data Controller, Convercent is responsible for safeguarding the data of visitors to the Site. As a Data Processor, Convercent is responsible for safeguarding the data of the End Users as it flows through the Convercent Ethics Cloud Platform.

Who is Your Data Controller? If you are a visitor to the Site, your Data Controller is Convercent, Inc. at 3858 Walnut Street, Suite 255, Denver, CO 80205, USA. Contact information is available at the bottom of this Privacy Policy. If you are an End User, then the Data Controller of your personal data is the respective Convercent client licensing the Convercent Ethics Cloud Platform and you should direct all questions about your personal data to that client.

What Is Personal Data? We collect information about you in a range of forms, including personal data. As used in this Privacy Policy, “personal data” is defined as in the European General Data Protection Regulation of 2018 (“GDPR”), and includes any information which, either alone or in combination with other information we hold about you, identifies you, including, for example, your name, postal address, email address and telephone number.

Why Do We Need Your Personal Data? We need certain personal data in order to deliver the Services to you.

Your Consent. By registering with Convercent or submitting personal data through our Services, you expressly consent to the collection, use and disclosure of your personal data in accordance with this Privacy Policy. We will process your personal data in accordance with applicable data protection and privacy laws. When you register with us, you are required to consent to our Privacy Policy. This consent provides us with a legal basis under applicable law to process your personal data. You maintain the right to withdraw such consent at any time.

Privacy Shield Participation

Convercent complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Convercent has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Convercent is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Convercent complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Convercent is subject to the investigation and regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Convercent may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Convercent commits to cooperate with the panel established by the EU data protection authorities (DPA’s) and the Swiss Federal Data Protection and Information Commissioner (FDIPC), with regard to unresolved Privacy Shield complaints concerning Human Resources and non-Human Resources data transferred from the EU and Switzerland.

Information We Collect

Convercent may collect information about you from various sources. Specifically, we may obtain information about you:

  • On the Site, through the Convercent platform, and through any of our mobile applications (e.g., when you request information on the Site, establish an account, or submit content to the Site);
  • When you call us, email us, or communicate with us through social media; and
  • From our affiliates or subsidiaries, service providers, business partners, and other third parties.

The types of personal information we may obtain include:

  • Contact details (e.g., name, postal address, email address, and telephone number);
  • Username and password for the account you may establish on our Site;
  • Photographs, videos, comments, and other content you submit to us;
  • Information you provide by interacting with us through social media; and
  • Other details that you may submit to us or that may be included in the information provided to us by third parties.

Automatic Data Collection

As is true of most web sites, we gather certain information automatically. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality and to analyze trends in the aggregate and administer the site. The information we may collect by automated means includes:

  • Information about the devices our visitors use to access the Internet (such as the IP address and the device, browser and operating system type);
  • URLs that refer visitors to our Site;
  • Dates and times of visits to our Site; and/or clickstream data
  • Internet service provider;
  • Referring/exit pages;
  • The files viewed on our site (e.g., HTML pages, graphics, etc.)
  • Language;
  • Information on actions taken on our Site (such as page views and website navigation patterns);
  • A general geographic location (such as country and city) from which a visitor accesses our Site or mobile applications; and
  • Search terms that visitors use to reach our Site.

Cookies.

Like many online services, we use cookies to collect information.  “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website.  We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience of our Services.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Services; and (2) third party cookies, which are served by service providers on our Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Our Services use the following types of cookies for the purposes set out below:

Type of cookiePurpose
Essential Cookies These cookies are essential to provide you with our Services and to enable you to use some of the features. For example, they help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality CookiesThese cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
Analytics and Performance CookiesThese cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Services works. You can find out more information about Google Analytics cookies here:  https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

You can find out more about how Google protects your data here: https://www.google.com/analytics/learn/privacy.html.

You can prevent the use of Google Analytics relating to your use of Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Targeted and advertising cookiesThese cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show ads which may be relevant to your interests while you are on third party websites.
Social Media CookiesThese cookies are used when you share information using a social media sharing button or “like” button on Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

 

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings.  Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.

Analytics

We may use third-party analytics providers (like Google Analytics and Mixpanel) to help analyze how users use the Services.  These analytics providers use cookies and other technologies to collect information such as how often users use the Services, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we get from these providers only to improve the Services. They collect the IP address assigned to you on the date you visit the Site, rather than your name or other personally identifying information.  We do not combine the information generated through the use of such analytics with your personal data. Although such services may set persistent cookies on computer to identify you as a unique user the next time you visit the Site, the cookie is designed to be used only by the service provider.

We use cookies to understand Site and Internet usage and to improve or customize the content, offerings or advertisements on our site. We also may use cookies to help us offer you products, programs, or services that may be of interest to you and to deliver relevant advertising.

We, our third-party service providers, advertisers or our partners also may use cookies to manage and measure the performance of advertisements displayed on or delivered by us and/or other networks or sites. This also helps us, our service providers and partners provide more relevant advertising.

We, our third party service providers, advertiser or our partners may also use “web beacons” or clear .gifs, or similar technologies, which are small pieces of code placed on a web page, to monitor the behavior and collect data about the visitors viewing a web page. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

How We Use the Information We Collect When Acting as a Data Controller

When you use or communicate with us through the Site, we may use the information we obtain about you to:

  • Register you on our Site and manage and maintain your accounts on the Site;
  • Provide products or services you request;
  • Understand your needs and interests and tailor our products and services to suit your personal interests and the manner in which visitors use our Site, products, and Services;
  • Communicate with you about products, services, based on the general geographic location transmitted by your mobile device;
  • Maintain a record of general transactions on our Site;
  • Respond to your questions and comments and provide customer support;
  • Communicate with you through email, websites, mobile applications and social media about our products, services, offers, events and promotions, and offer you products and services we believe may be of interest to you;
  • Enable you to communicate with us through our blogs, social networks, and other interactive media;
  • Operate, evaluate, and improve our business and the products and services we offer;
  • Analyze and enhance our marketing communications, and strategies (including by identifying when emails sent to you have been received and read);
  • Analyze performance of our services and technology and to analyze trends and statistics regarding visitors’ use of our Site, mobile applications, and social media assets, and the transactions visitors conduct on our Site;
  • Protect against fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
  • Enforce our Terms of Service; and
  • Comply with applicable legal requirements and industry standards and our policies.

We may combine the information we collect with publicly available information and information we receive from our affiliates, business partners, and other third parties which may include contact details (e.g., name, postal address, email address, and telephone number). We may use that combined information to enhance and personalize your experience with us, to communicate with you about products, services, and events that may be of interest to you, for promotional purposes, and for other purposes described in this Privacy Policy.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

Information Related to Convercent as a Data Processor

Convercent collects information when acting as a service provider to its clients. Convercent has no direct relationship with the individuals whose personal data it processes under the direction of our clients and our clients are responsible for making sure that your privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. To the extent that we are acting as a client’s data processor, we will process your information, including any personal data, in accordance with the terms of our agreement with the applicable client and the client’s lawful instructions and the terms of this Privacy Policy shall not apply to such processing. As part of the service to our clients, Convercent may operate an Ethics Cloud Platform for our clients to which the client’s privacy policy applies. If you are an End User of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly.

Access and Retention of Data Controlled by our Clients

Convercent acknowledges that you have the right to access your personal information. Convercent has no direct relationship with the individuals whose personal data it processes when acting as a data processor to our clients. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Convercent’s client, the data controller.

International Transfer

As part of the Services, your personal data, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in your country.  By using our Service, you consent and agree to this transfer, storing, processing and use of your personal data in accordance with this Privacy Policy.

Online Advertising

On our Site, we may collect information about your online activities to provide advertising about products and services tailored to your individual interests. You may see certain ads on the Site and other websites because we participate in ad networks. Ad networks allow us to target our advertising to users through demographic, behavioral, and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, Web server logs, Web beacons, and other methods. The networks use this information to show you advertisements for Convercent and our business partners that are tailored to your individual interests. The information our ad network vendors collect includes information about your visits to websites that participate in the vendors’ advertising networks, such as the pages or advertisements you have viewed, and the actions you take on websites. This data collection and ad targeting take place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

To direct our ad network vendors not to use your data to deliver targeted advertising to you, please contact us at marketing@convercent.com. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here, or if located in the European Union click here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. Some Web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates “Do Not Track” signals to the actual website differently making it unworkable to honor each and every request correctly. To alleviate any communication error between browsers and website, we do not respond to Web browser “Do Not Track” signals at this time for every browser type. As the technology and communication between browser and website improves, we will reevaluate the ability to honor every browser “Do Not Track” signals and may make changes to our policy.

Information We Share

We do not sell or otherwise disclose personal information about you, except as described in this Privacy Policy.

We may share the personal information we collect with our affiliates, business partners, ad network vendors and their participants, and other third parties for the purposes described in this Privacy Policy, including to communicate with you about products and services, offers, events, and promotions that we believe may be of interest to you. We also may share personal information with our service providers who perform services or process information on our behalf. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We also may disclose information about you (i) if we are required to do so by law such as to comply with a subpoena or other legal process (such as a court order), (ii) in response to a request by law enforcement authorities, or (iii) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

We reserve the right to transfer personal information we have about you in the event we sell, merge or transfer all or a portion of our business or assets, including pursuant to a bankruptcy or similar proceeding. Should such a sale, merger, or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Policy. Following such a sale, merger, or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information. You will also be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Your Rights When Convercent is Your Data Controller

If Convercent is your Data Controller as described above and you wish to exercise any of the following rights, please contact us using the details below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the rights you would like to enforce.  For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

Opt-out.  You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the Services may be ineffective upon opt-out.  Despite your indicated e-mail preferences, we may send you service-related communications, including notices of any updates to our Terms of Service or Privacy Policy.

Access. You may access the information we hold about you at any time by contacting us directly.

Amend. You can also contact us to update or correct any inaccuracies in your personal data.

Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.

Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

Sharing Information with Business Partners. You may direct Convercent not to share your personal information with our business partners for those partners’ own purposes. To do so, please adjust your preferences using the online account you may establish on our Site. If you opt out, we will continue sharing your information as otherwise described in the “Information We Share” section of this Privacy Policy, including with our service providers, to fulfill your requests and to comply with legal requirements.

Data Retention

Convercent will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Convercent will also retain customer data for a period of no longer than 365 days from date of termination of contracting party. The user account will remain active until responsible contracting company has either disabled the account or termination of service contract with Convercent.

How We Protect Personal Information

We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide on our Site and Ethics Cloud Platform against accidental unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. For example, You understand that other personal information (not including payment card information) may be transferred unencrypted and involve (i) transmissions over various networks and (ii) changes to conform and adapt to technical requirements of connecting networks or devices. However, Convercent will use commercially reasonable efforts, like secure socket layer (SSL), to encrypt information such as your login credentials during transmission.

Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.

Linked Websites and Social Networks

Our Site may provide links to third-party websites for your convenience and information. Convercent does not control linked websites, and we do not endorse or make any representations about third-party websites. Linked sites may have their own privacy policies, which you should review if you visit those websites. We are not responsible for the content of any websites not affiliated with Convercent, any use of those websites, or those websites’ privacy practices.

We may also provide social media features on our Site that enable you to share Convercent information with your social networks and to interact with Convercent on various social media websites. This includes social media features, such as the Facebook Like button and widgets, such as the Share this button or interactive mini-programs that run on our site. Your use of these features may result in the collection or sharing of information about you. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. We encourage you to review the privacy policies and settings on the social media websites with which you interact to help you understand those websites’ privacy practices.

Testimonials

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at marketing@convercent.com.

Children’s Privacy

Convercent does not knowingly collect Personal Information or direct its Site to children under the age of 16. If we learn that a user of the Site is under 16 years old, we will promptly delete any personal information that the individual has provided to us.

Updates to Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our Site to notify you of any significant changes to our Privacy Policy and indicate at the top of the Privacy Policy when it was most recently updated. If we make any material changes we will notify you by email sent to the e-mail address specified in your account or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

How to Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us by email at privacy@convercent.com. You also may write to:

Convercent
Attn: Convercent  Privacy Team
3858 Walnut Street, Suite #255
Denver, Colorado 80205

 

CONVERCENT POLICIES

At Convercent we value open and honest communication. We always make our most up-to-date policies easily accessible.