Privacy policy

Privacy Notice

Effective Date:  July 23, 2018

Overview

Telepath Data, Inc. dba Seventh Sense (“Seventh Sense”, “we” or “us”) knows that you care about how your personal information is used and shared - and we take your privacy seriously. This privacy notice ("Privacy Notice") applies to both our websites (Websites), including www.theseventhsense.com, and our Subscription Service, including our associated mobile applications (Mobile Apps). This explains our treatment of personally identifiable information ("Personal Information") that you submit, or Seventh Sense otherwise gathers, when you access or use the Service.

Processing activities covered

This Privacy Notice applies to the following processing activities:

  • Visiting our websites which display or link through to this Privacy Notice;
  • Visiting our offices;
  • Receiving communications from us, including emails, texts or fax;
  • Registering for our events;
  • Participating in community and open source development.

Our websites may contain links to other websites, applications and services maintained by third parties. The information practices of such other services are governed by the third-party privacy notices, which we encourage you to review to better understand those third parties’ privacy practices.

What Personal Data do we collect?

We collect information to provide better services to all our users. In fact, without collected information, our service would be almost worthless! We collect information in the following ways:

  • Information you give us. For example, you must provide us your name and email address as part of the registration process. Later, you’ll have to provide us with authorization for various services we gather data from.
  • Information you provide to our payment processor on our behalf. Our service never directly interacts with your payment information. Instead, we facilitate connecting you directly to our payment processor, Recurly, who takes care of keeping your subscription up to date and storing your card information in a secure manner. Should you have concerns about the storage of your payment information, Recurly’s privacy policy can be found at https://recurly.com/legal/privacy/. Such information will be used only for the purposes of processing payments to Seventh Sense for the Services.
  • Information we gather on your behalf. For example, after you’ve created an account you will probably want to create a “connector” to your marketing automation and/or email system. You will have to provide us with credentials or, whenever possible, an authorization grant. We will gather information from the connector and use it to build your profiles. Telepath Data does not access any information from these third-party services without your authorization.

What device and usage data we process?

Information we gather from your use of our service. As a part of our commitment to deliver the best possible services, we gather a variety of information on an ongoing information. This information includes details such as what pages you might have visited, details about errors you may have experienced, how long various operations took, etc. We gather this information in a variety of ways, including:

Logs

We automatically generate and and store certain of information whenever you interact with the Service. Such information may include your account id, IP address, domain server, and type of Internet browser. This information helps us, among other things, analyze trends and administer the Service.

Cookies, web beacons and other tracking technologies.

We use cookies and similar technologies such as web beacons, tags and Javascript alone or in conjunction with cookies to compile information about usage of our websites and interaction with emails from us.

When you visit our websites, our servers or an authorized third party may place a cookie on your browser, which can collect information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track overall usage, determine areas that you prefer, make your usage easier by recognizing you and providing you with a customized experience.

We use both session-based and persistent cookies. Session cookies exist only during one session and disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our websites or services. To opt-out from tracking by Google Analytics, please use the specific opt-out mechanism as indicated further below.

We also use web beacons on our websites. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. Such such tracking technologies are used to operate and improve our websites and email communications and track the clicking of links or opening of emails.

The following sets out how we use different categories of cookies and similar technologies, as well as information on your options for managing the settings for the data collection by these technologies:


Type of Cookies

Description

Managing Settings

Required cookies

Required cookies enable you to navigate our websites and use their features, such as accessing secure areas of the websites.

If you have chosen to identify yourself to us, we may place on your browser a cookie that allows us to uniquely identify you when you are logged into the websites and to process your online transactions and requests.

Because required cookies are essential to operate the websites there is no option to opt out of these cookies.

Functional Cookies

Functional cookies allow us to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features.


Functional cookies may also be used to improve how our websites function and to help us provide you with more relevant messages, including marketing communications. These cookies collect information about how our websites are used, including which pages are viewed most often.


We may use our own technology or third party technology to track and analyze usage and volume statistical information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.


In particular, we use Google Analytics ("Google Analytics"), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA as our processor. Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the websites visitors have come from, and the pages they visit. This information is used by us to improve our websites.

To manage the use of functional cookies on our websites, consult your individual browser settings for cookies. Note that opting out may impact the functionality you receive when using our websites.


To opt out from data collection by Google Analytics, you can download and install a browser add-on, which is available here.


To learn how to control functional cookies using your browser settings click here.


Opt-Out from the collection of device and usage data

You may opt-out from the collection of device and usage data (see "What device and usage data we process" section above) by managing your cookies at the individual browser level. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the website.

Purposes for which we process Personal Data and the legal basis on which we rely

  • Providing our websites: We will process your Personal Data to the extent this is necessary for the performance of our contract with you for the use of our websites and to fulfill our obligations under the applicable terms of use/service; where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our websites and to provide you with content you access and request (e.g., download of certain content from our websites);
  • Promoting security of our websites: We will process your Personal Data by tracking use of our websites, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity, as well as violations of and enforcement of our terms and policies, to the extent this is necessary for the purpose of our legitimate interests in promoting the safety and security of the systems and application used for our websites, and protecting our rights and the rights of others;
  • Managing user registrations: We will process your Personal Data by managing your user account for the purpose of performing the contract with you according to any applicable terms of service;
  • Handling contact and user support requests: If you fill out a “Contact Me” web form, request user support, or if you contact us by other means, we will process your Personal Data for the performance of our contract with you and to the extent it is necessary for the purpose of our legitimate interests to fulfill your request and communicate with you;
  • Managing payments: If you have provided financial information, we will process your respective Personal Data to check the financial qualifications and collect payments to the extent this is necessary for completing transaction with you under the contract entered into with you;
  • Developing and improving our websites: We will process your Personal Data to analyze trends, track your usage of our websites and interactions with emails to the extent this is necessary for our legitimate interests to develop and improve our websites and to provide our users with more relevant and interesting content;  
  • Sending marketing communications: We will process your Personal Data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interests to conduct direct marketing or to the extent you have provided your prior separate consent (please also view "Your rights relating to your Personal Data" section below to learn how you can control how your Personal Data is processed by Telepath Data for marketing purposes);
  • Complying with legal obligations: We will process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights, and is necessary for our legitimate interests to protect against misuse or abuse of our websites, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with a judicial proceedings, court order or legal process, and/or to respond to lawful requests.

Where we need to collect and process Personal Data by law, or under a contract we have entered into with you and you fail to provide that required Personal Data when requested, we may not be able to perform the contract.

Who do we share Personal Data with?

We may share your Personal Data with the following recipients:

  • Our contracted service providers which provide services such as IT and system administration and hosting, authentication, credit card processing, research and analytics, marketing, customer support and data enrichment.
  • In individual cases we may also share Personal Data with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers.
  • If we are involved in a merger or reorganization, sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by another company, we may transfer some or all of your Personal Data to such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any such transfer of Personal Data to an unaffiliated third party as processing of your Personal Data will be required for the purposes set out in "Purposes for which we process Personal Data and on which legal bases" section above.
  • For Legal Compliance. We may disclose your Information if required to do so by process of law, or if necessary in order to investigate fraud, a violation of our Terms of Use in connection with any harm being caused to a third party or their rights
  • With Your Consent. Except as set forth above, you will be notified when your Information may be shared with third parties, and will be able to prevent the sharing of this information.

International transfer of information collected

Your Personal Data may be collected, transferred to and stored by us in the United States and by our affiliates in other countries where we operate.


Therefore, your Personal Data may be processed outside the EEA, and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection in the EEA. In this event, we will ensure that such recipient offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

Children

Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us as described in the “Contacting Us” section below and we will take steps to delete such Personal Data from our systems.

Retention of Your Personal Data

We may retain your Personal Data for a period of time consistent with the original purpose of collection (see "Purposes for which we process Personal Data and on what legal basis" section above). We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of your Personal Data, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means, as well as the applicable legal requirements (such as applicable statutes of limitation).


After expiry of the retention periods, your Personal Data will be deleted. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of the data.

Your rights relating to your Personal Data

You have certain rights regarding your Personal Data, subject to local data protection laws. These may include the following rights:

  • to access your Personal Data held by us (right to access);
  • to rectify inaccurate Personal Data and ensure it is complete (right to rectification);
  • to erase/delete your Personal Data to the extent permitted by other legal obligations (right to erasure; right to be forgotten);
  • to restrict our processing of your Personal Data (right to restriction of processing);
  • to transfer your Personal Data to another controller to the extent possible (right to data portability);
  • to object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
  • not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making");  Automated Decision-Making currently does not take place on our websites;
  • to the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

How to exercise your rights

To exercise your rights, please contact us in accordance with the “Contacting Us” section below. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of a Telepath Data customer, we recommend you contact your company’s system administrator for assistance in correcting or updating your information.

In addition, if you have registered for an account with us, you may generally update your user settings, profile, organization’s settings or event registration by logging into the applicable website with your username and password and editing your settings or profile. To update your billing information, discontinue your account, and/or request return or deletion of your Personal Data and other information associated with your account, please contact us.

Your rights relating to Customer Data

As described above, we may also process Personal Data in the role of a processor. If your data has been submitted to us by a Telepath Data customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with our customer directly. Because we may only access our customer’s data upon instruction from the respective customer, if you wish to make your request directly to us, please provide the name of the Telepath Data customer who submitted your data when you contact us. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.

Your preferences for marketing communications

If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from us by clicking on the “unsubscribe” link located on the bottom of our marketing emails, by replying or texting ‘STOP’ if you receive SMS communications, or by turning off push notifications on our apps on your device. Additionally, you may unsubscribe here or by contacting us using the information in the “Contacting Us" section below. Please note that opting-out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as information about your subscriptions or event registrations, service announcements or security information.

Security

We take precautions including organizational, technical, and physical measures, to help safeguard against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the Personal Data we process or use.

While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us via the “Contacting Us” section below.

Changes to this Privacy Notice

We will update this Privacy Notice from time to time to reflect changes in our practices, technology, legal requirements and other factors. If we do, we will update the “effective date” at the top of this Privacy Notice. If we make an update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.

We encourage you to periodically review this Privacy Notice to stay informed about our collection, processing and sharing of your Personal Data.


Contacting Us

If you have any questions or concerns regarding our privacy practices, please send us a detailed message to privacy@telepathdata.com

or:

Telepath Data, Inc.,

2017 N Dinwiddie Street,

Arlington, VA 22207