Last Updated: 02/20/23
Steamroller Systems, Inc. (“Steamroller”) is committed to protecting and respecting your privacy. The purpose of this Privacy Notice is to set out the principles governing our use of personal information that we may obtain about you when you access the Switchchord Platform (the “Platform”), and the services that we provide via the Platform (collectively, the “Services”). By using the Platform or the Services, you acknowledge that you understand the matters described in this Privacy Notice.
Please read this Privacy Notice carefully. We may change our Privacy Notice from time to time, so you should check it occasionally to ensure that you are aware of the version that will apply each time you access the Platform or the Services. If we make changes, we will notify you by revising the date at the top of the Privacy Notice and, in some cases, we may provide you with additional notice (such as adding a statement to the homepage on the Site or by sending you a notification). BY ACCESSING OR OTHERWISE USING THE PLATFORM OR THE SERVICES, YOU AGREE TO THIS PRIVACY NOTICE. IF YOU DO NOT AGREE TO THIS PRIVACY NOTICE, DO NOT ACCESS OR USE THE PLATFORM OR THE SERVICES.
For your convenience, the Platform may contain links to a number of other websites. The privacy policies and procedures described here do not apply to those sites; we suggest contacting those sites directly for information on their data collection and distribution policies. Any reference to a linked site or any specific third party product or service by name does not constitute or imply its endorsement by us, and you assume all risk with respect to its use.
Collection of your Data
We may collect, use, store and transfer the following information to provide, improve and protect the Platform and our Services.
The data we collect and process. You may give us personal information by visiting or interacting with the Platform or the Services, registering for an account, participating in interactive features, filling in forms or surveys, uploading or downloading content on the Platform, signing split sheets or other documents, communicating with us, requesting customer support, or otherwise corresponding with us via phone, e-mail, or otherwise. This personal information includes the following data which are referred to in this Privacy Notice as ‘your data’, ‘your personal data’ or ‘your personal information’:
· Personal information you provide when you access the Platform or interact with the Services. The personal information you give us may include your name, title, company, mailing address, email address, phone number, password, and any other information you choose to provide to us.
· Technical data such as your internet protocol (IP) address, hardware model, operating system and version, device identifiers set by your device operating system, and mobile network information (like your connection type, carrier and region), your login data, the web page you visited before navigating to the Platform or the Services, browser type and version, app version, time zone setting and location, access times, browser plug-in types and versions, and other technology on the devices you use to access the Platform or the Services.
· Usage data which tells us how you use the Platform or the Services, including the sessions you use, the content you search for or access, what screens or features you access, and other similar types of usage information.
Data we generate. We may generate other information about you based on other information we have collected. For example, like most platforms, we use your IP address to derive the approximate location of your device. We may also use your first name to make an educated guess about your gender and use information about your activity to help determine the likelihood of you continuing to use our Services in the future.
Use of Your Data
We may use the data we collect to:
· Provide, maintain, evaluate. and improve the Platform and the Services, including debugging to identify and repair errors, and developing new products, features and services.
· Send you transactional or relationship messages, such as account notifications, customer service responses, and other administrative messages.
· Communicate with you about products, services and events offered by Steamroller and others, request feedback, and send news and other information we think will be of interest to you (see the "Your Choices" section below for information on how to opt out of marketing messages).
· Monitor and analyze trends, usage, and activities on the Platform and with the Services.
· Detect, investigate, and prevent fraudulent or illegal activities, and protect the rights and property of Steamroller and others, including to enforce our agreements and policies.
· Comply with legal or regulatory obligations, such as by processing transactional records for tax filings and other compliance activities.
· Personalize your online experience and the advertisements you see on other platforms based on your preferences, interests, and browsing behavior.
· Manage our relationship with you, which may include notifying you about changes to our Privacy Notice, Terms of Use, or other policies.
Sharing Your Data
When we share your data, we require the receiving party to have appropriate security measures in place and prohibit them from using the information for their own purposes or outside what is necessary to provide the service. We may share your data as follows:
· Among affiliates that share infrastructure, systems, and technology to process your data (as outlined in the sections above), as permitted by applicable law, and in accordance with this Privacy Notice.
Advertising and Analytics Services Provided by Others
We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, device identifiers, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Steamroller and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and online services, and better understand your online activity. For more information about interest-based ads, including to use ad industry tools to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Your mobile device should also include a feature that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.
Protecting your data
We use reasonable and appropriate physical, technical, and organizational security measures to protect your data against manipulation, risks of interception, data loss or corruption, destruction, access by unauthorized persons, viruses, or other harmful programs. Although we make every effort to ensure the protection, confidentiality, integrity, availability, resilience, and security of our network and systems, no method of safeguarding information is completely secure, and we cannot guarantee or warrant the security measures will protect all such information. The security of your data also depends on you. You accept and assume the inherent risks of online communication, including information you transmit to us online.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your choices
Account information. You may update certain account information you provide to us (such as your password, name and email address) by logging into your account or contacting us at info@switchchord.com. If you wish to disable your account, please contact us at info@switchchord.com, but note that we retain certain information when required or permitted by law. We also retain cached or archived copies of information about you for a certain period of time.
Promotional communications. You may opt out of receiving promotional emails from Steamroller by following the instructions in those emails or by logging into your account. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Data access and deletion. Subject to certain limits and conditions provided under law, we honor the exercise of the right of access or deletion for all of our users, regardless of their location. Any Steamroller user may exercise this right by contacting us at info@switchchord.com.
Your rights
Depending on applicable data protection and privacy laws, you may be entitled to a variety of legal rights regarding the collection and processing of your personal data. We respect your rights, and we will not discriminate or retaliate against you or the business with which you are associated as a result of you exercising any of the rights outlined below or afforded to you under applicable law. You can exercise any of these rights to the extent they apply to you by contacting us at info@switchchord.com. Note, however, that we may request certain reasonable additional information, that may include personal data, to help us authenticate your identity, your request and/or to clarify or understand the scope of your request. We will respond to a valid request within one month, or within three months when a request is complex or challenging.
Individual rights vary depending on the laws of the jurisdiction applicable to you, but may have the right to:
· Know what data is collected and shared. Upon request and as applicable, we will provide whether, and for what purposes and from what source, we collect and/or process your personal data, and whether and with whom we have shared your personal data, for what purpose, and what personal data has been shared.
· Access your data. Upon request and as applicable, we will provide any information relating to your data and our processing of your data in a concise, transparent, intelligible, and easily accessible form using clear and plain language.
· Opt-out of sale or sharing. You may have the right to opt-out of the sale or sharing of your personal data.
· Correct or modify your data. You may have the right to ask us to modify or rectify any inaccurate or incomplete personal data on our platform. If applicable and if we have given your personal data to any third parties, we will notify those third parties that Steamroller has received a request to rectify your personal data, unless doing so proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold; however, we are not in a position to audit those third parties to ensure that the rectification has occurred.
· Erase your data. In certain circumstances, you can ask us to erase or delete your personal data stored on our platform. If we receive a request to erase your data, we will ask you if you want your personal data to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose data we have erased so you may be contacted again by us, should we come into possession of your personal data at a later date. If we have given your personal data to any third parties, we will tell those third parties that Steamroller has received a request to erase your personal data, unless this proves impossible or involves a disproportionate effort. Those third parties should also rectify the personal data they hold; however, we will not be in a position to audit those third parties to ensure that the rectification has occurred.
· Object to profiling or automated decision-making. You may have the right to request information and to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you.
· Restrict the use of your data. We only process your personal data where we have the legal basis for doing so. You may have the right to ask us to suspend or otherwise restrict the processing of your personal data where you challenge the accuracy of the data, the processing is unlawful but you do not want us to erase it, you ask us to hold the data longer than required, or you have objected to our use of your data but we need to verify whether we have legitimate grounds to use it. If we have given the personal data to any third parties, we will tell those third parties that we have received a request to restrict the use of your personal data, unless this proves impossible or involves a disproportionate effort. Those third parties should also rectify the personal data they hold; however, we will not be in a position to audit those third parties to ensure that the rectification has occurred.
· Withdraw your consent. Where we are relying on consent to process your personal data (for example consent to receive marketing), you may have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
· Lodge a complaint. You may have the right to lodge a complaint with a regulator, including relevant supervisory authorities, located in the jurisdiction of your residence, place of work, or where an alleged violation of law occurred.
Use of Cookies and Other Tracking Technologies
Technologies such as cookies, tags and scripts may be used by Steamroller and our analytics or service providers. These technologies are used in analyzing trends, administering the Platform, tracking users’ movements around the Platform and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use cookies to maintain browser session information. No data is stored physically in the cookie. You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Platform, but your ability to use some features or areas of our Platform may be limited. We use the following types of cookies on our Platform:
Strictly necessary cookies: These cookies are necessary for our Platform to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of our Platform will not then work. These cookies do not store any personally identifiable information.
Performance and analytics cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Platform. They help us to know which pages are the most and least popular and see how visitors move around our Platform. The information that is collected by these cookies cannot be used to identify you. If you do not allow these cookies, we will not know when you have visited our Platform, and will not be able to monitor its performance.
Where we store and transfer your data
The Platform and the Services are controlled by Steamroller from its offices in the United States. Steamroller may store and use information in the United States and other jurisdictions; any personal data provided to Steamroller will be transmitted to or within those jurisdictions. Steamroller also may transfer information and personal data to other jurisdictions to facilitate Steamroller’s third party processors’ access to and/or processing of information and/or personal data. For individuals in the EU, whenever we transfer your personal data outside the European Economic Area (“EEA”), we ensure a similar degree of protection is afforded to it as in the EEA by using specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.
Steamroller makes no representation that materials on the Services are appropriate or available for use in other locations, and access to them from territories where their contents are illegal is prohibited. Those who choose to access the Services from other locations do so on their own initiative and are responsible for compliance with applicable local laws.
Contact us
If you have questions or concerns about the Services or this Privacy Notice, please contact us at info@switchchord.com.
Your California Privacy Rights
California Civil Code §1798.83 permits residents who have provided personal information to us to request information about our disclosure of personal information to third parties for their own direct marketing purposes. To make such a request or to opt-out of such disclosures in the future, please contact us at info@switchchord.com.
