Privacy Statement

Updated: August 2nd, 2023

Cireson, LLC, and its subsidiaries and affiliates (hereinafter “Cireson,” “we,” “us” or “our”) is committed to protecting your privacy. This Privacy Statement explains what personal data we collect, how this data is processed and for what purpose. in connection with our marketing activities, social media pages, our live events, and as otherwise described in this Privacy Policy. In addition, this Privacy Policy describes your rights and choices with respect to the personal information we collect. 

US State Data Privacy Notice: If you are a California, Virginia, Colorado, Connecticut, or Utah resident, see the Information for US State Residents section below for important information about your rights under State law. 

European Economic Area: If you are a resident of the European Economic Area, Switzerland, or the United Kingdom (collectively, “Europe”), see the information for Europe Residents below for important information. 

Cireson offers a range of products, on-premises and in the cloud, used to help enterprises across the globe operate. Cireson does not offer products or services for use by individuals for their personal, family or household purposes.  Accordingly, all personal information collected is treated as data pertaining to individuals in their capacities as representatives of the relevant enterprise and not their individual capacities. 

However, Cireson’s business customers may transmit or ingest personal information as part of the products and services provided to them. If you have concerns regarding personal information that we process on behalf of a business, please review their privacy policy and direct your concerns to that business. 

References to Cireson products and services in this statement include Cireson products, services, websites, apps, software, servers, and devices. 

Changes to this Privacy Statement 

We reserve the right to modify this Privacy Policy at any time. If we make significant changes, we will update the date of the policy and post it in all appropriate locations. If required by law, we will also notify you through other means that we believe will reach you, such as email (if we have your contact information) or another method within the Service. The updated Privacy Policy will become effective when we post the new terms or implement the changes in our products and services. By continuing to use our contracted products and services after we post any modified Privacy Policy, you indicate your acceptance of the updated terms. 

Security @Cireson 

We care about keeping your personal information safe. To safeguard the data we collect, we have implemented organizational, technical, and physical measures, and we validate the effectiveness of these measures through external independent audits. 

However, it’s important to know that there are always risks with technology and the Internet, Therefore, we cannot provide a complete guarantee of the security of your personal information. Please be aware that email, in particular, is not a secure method for transmitting sensitive information (unless you utilize email encryption technologies). Exercise caution when sharing any personal details with us via email. 

Personal data we collect 

We collect several types of information from and about our customers while providing and supporting our products and services. You provide personal information in the normal course of use of one of our products directly, for example when you create a support account or when you sign up for one of our services. 

We rely on a variety of legal reasons and permissions (sometimes called “legal bases”) to process data, including with your consent, a balancing of legitimate interests, necessity to enter into and perform contracts, and compliance with legal obligations, for a variety of purposes described below. 

The data we collect depends on the type of interactions you have with Cireson, the products and features you use, and applicable law.  

Personal data we collect can include the following: 

• General information, including a customer’s company name and address, credit card information, and the Customer’s representative’s name, email address and phone number. 
• Credentials, such as usernames and passwords used for authentication and account access. Please note that credentials that are gathered and maintained by us are stored securely using non-reversable encryption, and are not readable. 
• Payment data to process payments for our services. 
• Subscription and licensing data derived from your use of our products and services. For example, we may collect the number of active users within your instance. 
• Audit logs, activity logs, and error reports. We collect this information to ensure the availability and performance of systems and products. Even though these generally don’t contain personal data, in some cases – depending on the incident – a reference may be included.
• Interactions, which may include data about how you use or interact with Cireson products or our websites. 
• Data you enter into our systems. Content you communicate to us either directly or through the input, upload, or creation in our products and services. Examples are attachments, images, or text you may add to a support ticket, in our Cireson Community forum, or in an email communication. 
• Video or recordings. If you attend a Cireson online event or activity that is recorded, we may process your image and voice data.
• Feedback and ratings. This may include information you provide to us and the content of messages you send to us, such as feedback, survey data, and product reviews you write. 
• Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and any information you provide when you engage with our communications.
• Information we obtain from social media platforms. We may maintain pages for our Company on social media platforms, such as LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
• Information we obtain from other third parties. We may receive personal information about you from third-party sources, such as our business customers, marketing partners, publicly available sources and data providers. Our use of any information obtained from our business customers is restricted by our agreements with those business partners.
• Automatic data collection. Cireson and our service providers may log information about you, the device you are using and your interaction with the Service, such as: 
  • Device Data, such as your browser type and version, your operating system type and version, IP address, language settings, mobile network carrier, general location information, and various system telemetry values. 
  • Online activity data related to our products and services, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them. 
  • Communication and interaction data, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. 
• Cookies and similar technologies. Certain methods of automatic data collection mentioned earlier are made possible through the utilization of cookies and similar technologies. For further details, please consult the section titled “Cookies and Similar Technologies” below. Additionally, we will retain a log of your preferences regarding the usage of these technologies in relation to the Service. 

How we use personal data 

Links or references to other Sites and Services

Our products and services may include links to third-party websites and online services. These links should not be seen as an endorsement or indication of any affiliation with such third parties. Furthermore, our content may appear on web pages or online services that are not directly associated with us. We do not have control over these third-party websites or online services, and we cannot be held responsible for their actions. It’s important to note that different websites and services have their own privacy policies, which may vary in terms of how they collect, use, and share your personal information. We strongly encourage you to review the privacy policies of any other websites and online services you utilize.

Children

Cireson products and services are designed for business purposes and are meant to be used by businesses. They are not intended for, and we don’t collect personal information from, individuals under the age of 18 knowingly. If we discover that someone under 18 has provided us with personal information without proper authorization, we will delete that information from our records as soon as reasonably possible.

US State Data Privacy Notice 

The California Consumer Privacy Act of 2018 (“CCPA”) became effective on January 1, 2020 and created a variety of privacy rights for California consumers. In November 2020, California amended the CCPA, effective January 1, 2023. Additionally, Virginia (effective January 1, 2023), Colorado (effective July 1, 2023), Connecticut (July 1, 2023), and Utah (December 31, 2023) have passed laws extending similar privacy rights to their consumers. We use this notice to make disclosures required by these state laws. 

Please note that the rules implementing some of these laws have not yet been finalized. We are continuously working to better comply with these laws, and we will update our processes, disclosures, and this notice as these implementing rules are finalized. 

Scope: This section specifically applies to residents of California, Virginia, Colorado, Connecticut, and Utah (hereinafter the “states”). It explains how we handle the collection, use, and sharing of Personal Information both online and offline, as a “business” under the applicable state laws. It also outlines the rights that residents of these states have in relation to their Personal Information. Please note that certain categories of California residents, such as job applicants, may receive a different privacy notice that will take precedence over this section. 

Your privacy rights: As a resident of these states, you have certain rights, which include the following. However, it’s important to note that these rights are not absolute, and there may be cases where we are permitted by law to deny your request.

• You can request the following information about how we have collected and used your Personal Information during the past 12 months: 
  • • The categories of Personal Information that we have collected; 
    • The categories of sources from which we collected Personal Information;
    • The business or commercial purpose for collecting, selling and/or sharing Personal Information;
    • The categories of third parties with whom we disclose Personal Information;
    • The categories of Personal Information that we sold, disclosed, or shared for a business purpose; and
    • The categories of third parties to whom the Personal Information was sold, shared or disclosed for a business purpose. 

• You can request a copy of the Personal Information that we have collected about you during the past 12 months. 
• You can ask us to delete the Personal Information that we have collected from you. 
• You can ask us to correct inaccurate Personal Information that we have collected about you. 
• You can request to opt-out of disclosures of your Personal Information that constitute “selling” or “sharing” of your Personal Information as defined in the state laws. 
• You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA and other state laws. 

Exercising your right to information, access, correction and deletion. You may submit requests to exercise these rights in the above section, “How to Contact Us.” 

Notice of right to opt-out of the “selling” or “sharing” of your Personal Information. As described above, Cireson does not engage in interest-based ads to you as described in the How We Use Personal Data section above. As such, Cireson does engage in what may be classified under the state laws as a “selling” or “sharing” your Personal Information (including any business and personal contact information, device data, and online activity data described above in “Personal information we collect” section above). 

Verification of identity or authorized agents.  To process your information, access, correction, and deletion requests, we need to verify your identity and confirm your state residency. This is to ensure the security of your personal information. In order to verify your identity, we may ask you to authenticate through an online account with us (if you have one), provide information that we can compare with our records, show a government-issued identification, make a declaration under penalty of perjury, or provide other information allowed by law. 

If you want to authorize someone else (an authorized agent) to make a request on your behalf, we will need to verify their identity as well. They must provide us with a valid power of attorney according to applicable state laws (e.g. for California residents: California Probate Code Sections 4000-4465). If you have not granted your authorized agent a power of attorney, you must give them written permission, sign it, and confirm in writing that you have authorized them to exercise your rights under the CCPA or other applicable state laws. Additionally, they must provide the information we require to verify your identity. 

Personal information that we collect, use and disclose. The table provided below gives a summary of the Personal Information we collect, categorized according to the specifications provided in the CCPA and CPRA. It outlines our current practices as well as those within the 12 months prior to the effective date of this Privacy Policy. It’s important to note that the information you voluntarily provide to us, such as through free-form web forms, may include additional categories of personal information that are not specifically mentioned in the table. 

Information for Europe Residents 

The information provided in this section applies only to individuals in the European Economic Area, Switzerland, and United Kingdom (collectively, “Europe”). 

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal information” governed by European data protection legislation. 

Controller. Cireson is the controller of your personal information that is actively collected for the purposes of providing and improving the product or service.   

Processor. Cireson is a processor of your personal information that is entered or ingested by you or your organization into systems and services operated and maintained by us. Please note that we are not aware, nor do we control the nature, category or volume of data that is entered and used by you and your organization. 

Our GDPR representatives. Cireson does not process large amounts or special categories of data as referred to in GDPR Art. 9 (1), nor personal data relating to criminal convictions and offenses referred to in GDPR Art. 10. Thus, pursuant to GDPR Art. 27 (2)(a) Cireson does not currently maintain representation in Europe. Cireson will take appropriate steps, based on the requirements of our customers. 

Legal bases for processing. We use your personal data for the purposes listed below. In respect of each of the purposes for which we use your personal data, European data protection legislation requires us to ensure that we have a “legal basis” for that use. We rely on the following legal bases: 

• Consent: Processing personal data is based on the clear and voluntary agreement given by the individual for a specific purpose. Consent should be well-informed, straightforward, and provided through clear and affirmative action. 
• Contractual Necessity: Processing personal data is necessary to fulfill obligations under a contract between the individual and the organization. This basis applies when data processing is required to carry out the terms of a contract or take steps before entering into a contract. 
• Legal Obligation: Processing personal data is necessary to comply with a legal requirement imposed on the organization. This includes obligations set by laws or regulations, such as tax or employment laws. 
• Legitimate Interests: Processing personal data is necessary for the legitimate interests pursued by the organization or a third party, except when those interests are outweighed by the individual’s rights and freedoms. Legitimate interests may include business purposes, direct marketing, fraud prevention, or IT security. 

Use for new purposes. We might use your personal information for purposes that are not specifically mentioned in this Privacy Policy, but only if it’s allowed by law and aligns with the original reason we collected your information. If we ever need to use your personal information for a different purpose, we will let you know and clarify the legal basis that applies to it. 

Data Sharing and Transfers. We may share your personal data with trusted third parties, including service providers and business partners, for the purposes outlined in this privacy statement. We ensure appropriate safeguards are in place to protect your data when sharing it with third parties. 

If we transfer personal data to countries outside the European Economic Area (EEA), we will implement appropriate measures to ensure an adequate level of data protection as required by applicable data protection laws. 

Data Subject Rights. Under the GDPR, you have certain rights regarding your personal data, including: 

• Right to access: You can request access to the personal data we hold about you. 
• Right to rectification: You have the right to request correction of inaccurate or incomplete data. 
• Right to erasure: You can request the deletion of your personal data under specific circumstances. 
• Right to restrict processing: You have the right to restrict certain processing activities. 
• Right to data portability: You can request the transfer of your personal data to another organization. 
• Right to object: You have the right to object to certain processing activities based on legitimate interests. 

To exercise your rights or obtain further information about them, please contact us using the details provided in the How to Contact Us section. 

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with how we handle your request or process your personal information, you have the option to lodge a complaint with the data protection authority in your country of residence.

• For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here.
  
• For users in the UK – the contact information for the UK data protection regulator is below: 
  The Information Commissioner’s Office 
  Water Lane, Wycliffe House 
  Wilmslow – Cheshire SK9 5AF 
  Tel. +44 303 123 1113 
  Visit Website
• For users in Switzerland – the contact information the Swiss data protection regulator can be found here.