Privacy Policy

Summary:

Full Privacy Policy

Please read this Privacy Policy carefully and let us know if you have any questions or require any clarification.

By accessing the content on 33voices.com or using our services otherwise defined below, you acknowledge that you have read, understood, and agree to be bound to all the terms and conditions of this Privacy Policy, and the “Terms of Use” or other customer agreement between you and 33voices, Inc that is applicable to the particular service you are using or accessing (collectively, “User Agreements”).

If you do not agree to this Privacy Policy and the applicable User Agreements, please exist our site and cease from accessing or using our service.

The Privacy Policy does not apply to the practices of third parties, as explained in more detail below. In this “Privacy Policy, “we,” “us,” “our,” and other similar references mean 33voices, Inc; “you” and “your” and other similar references mean any user of our service, and “33voices Affiliates” means any parent, subsidiary, member, officer, director, employee, agent, or contractor of 33voices, Inc or any entity under common control with 33voices, Inc.

This policy applies (i) immediately to new users who use or access the Service on or after the Effective Date and (ii) on the Effective Date to users who use or access the service before the Effective Date.

Transfers of Personal Data

This Service is hosted and operated in the United States (“U.S”). If you do not reside in the U.S., laws in the U.S. (and other countries) may differ from the laws where you reside. By using the Service, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to 33voices, Inc in the U.S. And will be hosted on U.S. Servers, and you authorize 33voices, Inc to transfer, store, host and process your information to and in the U.S., and possibly other countries. You hereby consent to transfer of your data to the United States.

EU Personal Data

If you are located in the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) related to your Personal Data, as further described below. 33voices, Inc will be the controller of your Personal Data processed in connection with the Service, unless you access the Service through an account that is controlled by a third party (e.g. Your employer).

Notice of What Information We Collect and How We Use It

Types of Personal Data We Collect: 33voices, Inc collects Personal Data about you when you provide it directly to us, when third parties such as your employer provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Service. We collect the following Personal Data from you in connection with the Service:

We also collect usage and performance information that is not Personal Data or that we aggregate or de-identify so that it no longer personally identifies an individual. We also associate some data that is not Personal Data with Personal Data.

We collect Personal Data when a user:

Some of the methods and tools we use to collect Personal Data are:

Use of Personal Data

33voices, Inc uses Personal Data to:

For example, we use Personal Data to:

Processing Grounds

We will only use your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data because we need to process the data to perform under our User Agreement with you, which enables us to provide you with the Service. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Service that require such data:

Legitimate Interest: We process the following categories of Personal Data when we believe doing so furthers the legitimate interest of us or third parties:

Examples of these legitimate interests include:

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other processing Grounds: From time to time we cay also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Does 33voices, inc Share Personal Data?

We share Personal Data with vendors, third party service providers, and agents who work on our behalf and provide us with services related to the Service. These parties include:

We also share Personal Data when we believe it is necessary to:

Business Transfers

33voices, Inc may sell, transfer, or otherwise share some or all of its business or assets, including your Personal Data, in connection with a business deal (or the evaluation of a potential business deal) such as a merger, consolidation, acquisition, reorganization, or sale of assets or in the event of bankruptcy. You acknowledge that such transfers may occur and that any acquirer or successor of 33voices, Inc or its assets may continue to use your Personal Data as set forth in this Privacy Policy. You will be notified via email and/or prominent notice on our Website or Service of any change in ownership or resulting change in uses of your Personal Data, as well as any choices you may have regarding your Personal Data.

Opting Out of Tracking Tools

Service Provide Opt Out: You can opt-out directly from some providers of Tracking Tools by using their opt-out tools. Some of these services providers, and links to their opt-out tools, are:

Industry Opt Out Tools: Some Advertising Service Providers or providers of Tracking Tools may participate in the Network Advertising Initiatives (NAI) Opt-Out Tool - http://www.networkadvertising.org/choices/ - and/or the Digital Advertising Alliance (DAA) Consumer Choice Page - http:// www.aboutads.info/choices/ - and you can opt-out of certain services and learn more about your choices by visiting the links included there. Users in the EU can visit - http://www.youronlinechoices.eu/ - for more information about your choices and to opt out of participating service providers.

Web Browser Controls: You can prevent the use of certain Tracking Tools, such as cookies, on a device-by-device basis using the controls in your web browser. These controls can be found in the Tools > Internet Options (or similar) menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to:

Mobile Opt Out: Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for Behavioral Advertising. You may also opt-out of certain Tracking Tools on mobile devices by installing the DAA’s AppChoice app on your mobile device (for iTunes, visit - https://itunes.apple.com/us/app/appchoices/ id894822870?mt=8 - for Android, visit - https://play.google.com/store/ apps/details?id=com.DAA.appchoices&hl=en. For more information, please visit http://support.apple.com/kb/HT4228, https://support.google.com/ads/answer/2662922?hl=en or http://www.applicationprivacy.org/expressing- your-behavioral-advertising-choices-on-a-mobile-device as applicable.

Do Not Track: Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. The Service does not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Service and after you leave our Service.

Information Shared with Third Parties: Except as set forth in this Privacy Policy, you will be notified when your Personal Data may be shared with third parties, and will be able to prevent the sharing of this information. To the extent permitted or required by applicable law, you can opt-out of having your information shared with a third party that is not our agent, by contacting us at team@33voices.com. However, please note that opting-out of information sharing or collection may affect your ability to use some features of the Service.

Security

We believe the security of your information is a serious issue and we are committed to protecting the information we receive from you. We use commercially reasonable security measures to protect against the loss, misuse, and alteration of your information under our control based on the type of Personal Data and applicable processing activity, such as data encryption in transit, pseudonymization, and enforcement of least privilege and need-to-know principles.

To the extent the Service requires you to provide any Financial Account Information, that information will be collected and processed by third-party PCI-compliant service providers. We do not store Financial Account Information transmitted through the Service, provided that we do store (or our payment processor on our behalf will store) just the last four digits of your credit card number, if you provide this to us, to comply with credit card processing requirements of authorizations, charges and chargebacks.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with the Service, and thereafter as set forth in our Service agreement with you (typically 30 days after termination of the Service, or sooner upon request (except as required by law)). In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. Upon disposal, we will destroy or render unreadable any such Personal Data. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

Interactions with Others

The Privacy Policy applies only to the Service. It does not apply to products, services, or sites that are provided by or operated by third parties, even if such products, services or sites are linked or redirected to or from the Service (“Third-Party Sites”), regardless of whether or not such link or redirection is authorized by 33voices, Inc. Third-Party Sites may have their own policies regarding privacy, or no policy at all. The fact that we link to a Third-Party Site is not an endorsement, authorization, or representation that we are affiliated with that third party. 33voices, Inc is not responsible for Third-Party Sites, and you use them at your own risk. We encourage you to read the privacy policies and terms of the Third-Party Sites that you visit or use.

What Rights and Choices do you Have Regarding Your Personal Data?

Accessing, Correcting, and Deleting Your Personal Data and Other Data Subject Rights -
You have certain rights with respect to your Personal Data, and we want to help you review and update your information to ensure it is accurate and up- to-date. We may limit or reject your request in certain cases, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, if it is not required by law, or if the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question. In some cases, we may also need you to provide us with additional information, which may include Personal Data, to verify your identity and the nature of your request. We will take reasonable steps to respond to all requests within 30 days (or less!).

For the following, please email team@33voices.com.

Withdrawal of Consent - If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Service.

Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for marketing purposes.

Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.

Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.

Erasure: You can request that we erase some or all of your Personal Data from our systems. Please note that if you request the deletion of information required to provide the Service to you, your User Account will be deactivated and you will lose access to the Service.

Portability: You can ask for a copy of your Personal Data in a machine- readable format. You can also request that we transmit the data to another controller where technically feasible.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of Personal Data that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of Personal Data that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by 33voices, Inc pursuant to Section 1798.83 of the California Civil Code, please contact as set forth above.

Enforcement and Recourse

We take our privacy commitments very seriously. We will conduct internal audits of our compliance with this Privacy Policy, and work to ensure that our employees and service providers also adhere to the Privacy Policy. If you have any questions or concerns regarding privacy related to the Service, please send us a detailed message to team@33voices.com and we will try to resolve your concerns.

Changes to The Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, you will be notified via email (if you have an account where we have your contact information) or otherwise in some manner through the Service that we deem reasonably likely to reach you (which may include posting a new privacy policy on our Website—or a specific announcement on this page). Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting) or on the Effective Date set forth in the modified Privacy Policy. In all cases, your continued use of the Service or Website after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Children

Our Service is not intended for individuals under the age of 18, and therefore, 33voices, Inc does not knowingly acquire or receive Personal Data from children. If we later learn that any user of our Service is under the age of 18, we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Service.

IF YOU HAVE ANY FURTHER QUESTIONS ABOUT YOUR PERSONAL DATA, PLEASE FREE TO CONTACT US AT team@33voices.com

Last Updated: May 25, 2018