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Assembled Privacy Policy

Assembled Inc. (“Assembled”, “we”, or “us”) provides this Privacy Policy to inform you of our policies and proceduresregarding the collection, use and disclosure of information we receive fromusers of our website (such as www.assembled.com) and our products, services, and applications(collectively, the “Services”), or when you attend an Assembled event orotherwise interact with us. This Privacy Policy applies to visitors of ourwebsites and individuals registered for our Services (“Users”, “you”, or“your”), including Users who are provisioned an account by our customers(“Customers”). Your privacy is important to us.  Please read this policycarefully to understand how we will collect, use, and disclose yourinformation, and what choices you have with respect to your information.

Information we collect from you and why

We collect and use the following information to provide, improve, promote, and protect the Services:

  • When you register with us through the Services to become an Assembled User, we will ask you for information relating to an identified or identifiable natural person ("Personal Data"). We may request you to provide Personal Data such as your name and email address.  We collect information, including Personal Data, that you submit to the Services. Our Customer’s administrator (“Admin”) may also direct us to collect your work availability and other information. We use your Personal Data to provide the Services to you and our Customer and to administer your inquiries.
  • We also collect Personal Data that: (a) the Customer has provided to the Services directly or (b) that the Customer has provided to the Services indirectly through a third-party service (e.g., GSuite, Zendesk, etc.). We may use this information to provide the Services to you and our Customer.
  • If you express interest in obtaining information about our Services, sign up for an event or webinar, provide our business partner with your information, or download certain content, we may require you to provide us with Personal Data such as your name, email address, address, phone number, title, company name, and other information.  We use this information to promote the Services to you with Assembled newsletters, marketing, or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications.
  • We may collect information from you in surveys that we may conduct in order to improve the Services.
  • We may accept financial and billing information in order to process your payment for use of the Services.

What information we collect from devices and usage and why

We use typical tools and services, such as log files, cookies, pixel tags, and similar technologies to automatically collect information, which may contain Personal Data, from your devices while you navigate our Services or interact with emails we sent to you.

  • When you use the Services, we may collect information about the devices you use to access the Services, including IP address, browser or device type, operating system, the website you visited before the Services, and identifiers of your devices.  We use this information to provide, improve, and protect the Services.
  • When you interact with our Services, we collect information about how you use the Services, including tracking Users’ activity in our Services.  We use this information to provide and improve the Services, and to protect the Services. We may also provide the Customer’s Admin with this information.
  • We use cookies, tracking pixels, and similar technologies by working with our trusted third-party service providers, including Google Analytics, to provide, improve, protect, and promote our Services. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your username and password for future logins to the Services. Second, we utilize session ID cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by visitors and Users and web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.  If you do not accept cookies, however, you may not be able to use all portions of the Services. A tracking pixel is a unique identifier embedded in a website, online advertisement, or email. We use tracking pixels to understand how you interact with our websites and emails and helps us and our advertising service providers better promote our Services. We also use HTML5 local storage objects (“HTML5 LSOs”) or Flash local storage objects (“Flash Cookies”) to store content information and preferences. Our website does not respond to Do Not Track signals.

Your choices

You also have choices with respect to technologies we use to automatically collect information as described below:

How we use information

We collect and use the Personal Data described above in order to provide, improve, promote, and protect the Services, and to develop new products and services.  We also collect and use Personal Data for our legitimate business needs. To the extent we process your Personal Data for other purposes, we or our trusted third-party service providers will ask for your consent.  We may aggregate or de-identify information submitted to or collected by use of the Services so that the information does not identify you or Customer. This Privacy Policy does not restrict our use or disclosure of aggregated or de-identified information that complies with applicable law.

Information sharing and disclosure

We use your Personal Data as described below, but we don’t sell it to advertisers or other third parties.

  • If your User account was provisioned by a Customer, your Admin may have access and control over the information associated with your account.  The Customer may have its own policies governing access and use of information in your User account.
  • Depending on a Customer’s settings and your choices, we will share certain information with other Users that are part of a Customer account.
  • Assembled uses certain trusted third-party service providers to help us provide, improve, protect, and promote our Services.  These third parties may have access to your information to perform services on our behalf and in compliance with this Privacy Policy.  We will be responsible for the third parties we use to perform services on our behalf.
  • You or your Admin may provide a third-party service with access to your information.  The use of such information by a third-party service will be governed by the third-party service’s privacy policy.
  • We may share your information, including Personal Data, with Assembled’s affiliates to provide, improve, protect, and promote the Services, or communicate with you.
  • We may disclose your information to third parties if we determine such disclosure is reasonably necessary to: (a) comply with applicable law, regulation, legal process, or government request, (b) protect any person from death or serious bodily injury, (c) prevent fraud, abuse, or security issue of Assembled or other users, and (d) to protect Assembled’s or its licensors’ rights, property, safety, or interest.
  • We may also disclose or share your Personal Data with your consent.

Business Transfers

Assembled may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy.

Data modification, deletion, and retention

You may have the right to access, review, correct, amend, restrict, delete, opt-out of, or object to our use of the Personal Data provided to Assembled by contacting us at privacy@assembled.com .  If your User account was provisioned by a Customer, the Customer is a “data controller” of your information, and if you seek to correct, amend, or delete data associated with your account, you should direct your requests to the Customer.

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

For EU individuals: Privacy Shield Notice for Personal Data Transfers to the United States

Assembled complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries (and Iceland, Liechtenstein, and Norway) and Switzerland transferred to the United States pursuant to Privacy Shield. Assembled has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Assembled is subject to the regulatory and enforcementpowers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@assembled.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@assembled.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Assembled’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Assembled remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Assembled proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Assembled commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield inquiries or complaints should first contact Assembled by email at privacy@assembled.com or via post at:

1870 Jackson St.
Unit 304
San Francisco, CA 94109

Assembled has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Security

Assembled is concerned with safeguarding your information.  Assembled employs reasonable physical, technological, and administrative security measures.  No method of transmission of over the Internet, or method of electronic storage, is 100% secure, however.  Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Links to other websites

Our Services may contain links to, or interoperate with third-party services.  When you click on a link to any other website or location, when you or the Customer provides a third-party service with access to information in your account, such third-party may then collect or access information from you or Customer.  The use of such information, including Personal Data, by the third-party service will be governed by the third-party service’s privacy policy. We have no control over, do not review, and cannot be responsible for, these third-party services. We encourage you to read the privacy policies of every website you visit and every third-party service you use.

Our policy on children

The Services are not directed to individuals under 13, or a higher age depending on your jurisdiction (“Required Age”).  If Assembled becomes aware that a child under the Required Age has submitted information to us, we will delete the information.  If you believe that we may have any information from a child under the Required Age, please contact us at privacy@assembled.com.

Modification of privacy policy

Assembled may modify this Privacy Policy from time to time. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the website. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contacting us

If you have questions about this Privacy Policy, please contact us at privacy@assembled.com or at our mailing address below.

1870 Jackson St.
Unit 304
San Francisco, CA 94109