Background

Privacy Policy

Last revised on and effective as of September 07, 2016.

Protecting consumer privacy is important to Emshee. This Privacy Policy explains how information about you is collected, used and disclosed by Emshee, LLC ("Emshee", "we", "us" or "our"). This Privacy Policy applies to information we collect when you use our websites, mobile applications, and other products and services (collectively, the "Services") or when you otherwise interact with us whether in electronic, paper or verbal format. This Privacy Policy does not apply to any information we collect about industry professionals who may provide counseling services to users of our Services.

Emshee is based in the United States and the information we collect is governed by United States ("US") law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the US and other countries, except in the case of transfers from the European Economic Area or Switzerland, which are covered under the European Union ("EU") Safe Harbor Frameworks.

We adhere to the US-EU Safe Harbor Framework and US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information from European Union ("EU") member countries and Switzerland. Emshee has certified that it adheres to the Safe Harbor Privacy Principles (the "Principles") of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit Export.gov. If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern. For purposes of the Principles, "Personal Information" is defined as (1) information that is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as by adding a statement to our websites or by sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

Information You Provide To Us

We collect information you and your employees, affiliates or contractors provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services, fill out a form, complete a survey, make a purchase, request customer support or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, payment information and any other information you choose to provide.

Information We Collect Automatically When You Use the Services

When you access or use our Services, we automatically collect information about you, including:

Log Information:

We collect log files in connection with your interactions with our Services, including the type of Internet browser you use, the time and day of access, the web pages viewed within our Services, the web page you visited before navigating to our Services, and the IP address of the computer or mobile device you use to access our Services.

Device Information:

We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.

Location Information:

We may collect information about the location of your device each time you access or use one of our mobile applications or other location aware software connected to our services or otherwise consent to the collection of this information. For more details, please see "Your Choices" below.

Website Interaction Information:

We may record mouse clicks, movements and other interactions with our web pages to help us improve site usability.

Information Collected by Cookies and Other Tracking Technologies:

We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your computer's hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see "Your Choices" below. We may also collect information using web beacons (also known as tracking pixels), which are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Information We Collect From Other Sources:

We may also obtain information from other sources and combine that with information we collect through our Services. For instance, we may collect Personal Information from you via our web site from a request that you make for additional information about the Company or our Services.

Use of Information

We may use information about you and that you provide for various purposes, including to:

  • Provide, maintain and improve our Services;
  • Provide and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices;
  • Send you technical notices, updates, security alerts and support and administrative messages;
  • Respond to your comments, questions and requests and provide customer service;
  • Communicate with you about products, services, offers, promotions, rewards, and events offered by Emshee and others, and provide information we think will be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Process and deliver contest entries and rewards;
  • Link or combine with information we get from others to help understand your needs and provide you with better service; and
  • Carry out any other purpose necessarily contemplated by the collection of information about you or as otherwise notified via the Services at the time of collection.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
  • In response to a request for information if disclosure is required by, or if we believe disclosure is in accordance with, any applicable law, regulation or legal process;
  • If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Emshee or others;
  • In connection with, or during negotiations of, any merger, sale of Emshee assets, financing or acquisition of all or a portion of our business to another entity; and
  • With your consent or at your direction, including if we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified information with third parties, which cannot reasonably be used to identify you.

Analytics Services Provided by Others

We may allow others to provide analytics services on our behalf via the Services. These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by Emshee and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

Security

Emshee uses accepted best methods and takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We review our security procedures carefully and regularly and our staff is trained and required to safeguard your information. We transmit, store, protect and access all cardholder information in compliance with the Payment Card Industry's Data Security Standards.

Your Choices

Emshee Account Information

You may update, correct or delete your Emshee account profile information at any time by logging into your online Emshee account. Please note that we may retain certain information as required by law or for legitimate business purposes.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies our mobile applications, or certain features thereof, will no longer function.

Location Information

When you first launch any of our mobile applications that collect location information, you will be asked to consent to the application's collection of this information. We currently require this location information in order to use our Services, so if you do not consent to this collection, you cannot use our Services. If you initially consent to our collection of location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. If you do so, our mobile applications, or certain features thereof, will no longer function. You may also stop our collection of location information by following the standard uninstall process to remove all of our mobile applications from your device.

Promotional Communications

You may opt out of receiving promotional communications from Emshee by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, previous purchases or our ongoing business relations.

Your California Privacy Rights

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us or call us toll free at 888.836.2720. However, please note that under the law, Services such as ours that permit California residents to opt in to, or opt out of, this type of sharing are not required to provide such information upon receiving a request, but rather may respond by notifying the user of his or her right to prevent the disclosure. To opt out of having information about you shared with third parties for direct marketing purposes, please contact us.

Contact Us

Questions, comments or complaints regarding Emshee's Privacy and Safe Harbor Policy or data collection and processing practices please contact us at support@emshee.com. Emshee has further committed to refer any unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your inquiry is not satisfactorily addressed by Emshee, please visit the BBB EU Safe Harbor web site for more information and to file a complaint.

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