Last revised and effective as of: June 30, 2020
What information about me is collected?
Does Monocl collect information from children under 13 years of age?
What does Monocl do with the information it collects?
When does Monocl disclose information to third parties?
Could my information be transferred to other countries?
For how long will my personally identifiable information be kept?
What choices do I have regarding my personally identifiable information?
Who do I contact if I have any privacy questions?
Special Notice for California Residents.
1. WHAT INFORMATION ABOUT ME IS COLLECTED?
Depending on your use of the Site or our interactions with you, we may collect two types of information: personally identifiable information and non-personally identifiable information.
Personally Identifiable Information
Non-Personally Identifiable Information
Non-personally identifiable information is information, any single item of which, by itself, cannot be used to identify or contact you, including non-identifiable demographic information, language, internet service provider, browser types, browser system, unique device identifiers, email client, device types, requested URL, referring URL, traffic source, browser language, the pages you view, content you engage with, the date and time of your visit, the duration of your visit, location (city, country, continent), operating system, domain names, and statistical data involving the use of the Site. We also collect aggregated statistics connected to support issues. Certain non-personally identifiable information may be considered a part of your personally identifiable information if it were combined with other identifiers in a way that enables you to be identified. However, the same pieces of information are considered non-personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example, your viewing preferences) in a way that would not enable you to be identified.
We collect personally identifiable information that you submit to us, including when you subscribe to our newsletter, request a demo, or if you engage in an instant message “chat” with one of our representatives on the Site. We may receive personally identifiable information from or about you when we meet you at an Event, when you sign up for or participate in a Webinar, or when you contact us for a Support Call. If we receive a question for support, we collect and store the question as well as the answer to the question. We also collect aggregated statistics connected to support issues. We may also receive lists of contact information from commercial partners with whom we partner to present Webinars. We may also receive information about you from other third parties, such as search information providers, providers of meta-data about Site visitors, and lead generation services, and we may directly collect personal information about you that is publicly available from sources such as LinkedIn and other publicly available websites.
Cookies and Action Tags.
We may collect information passively using “cookies” and “action tags.”
“Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Site and other websites. Cookies can be used to personalize your experience on the Site (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Site (such as saving time by not having to reenter your name each time you use the Site), to allow us to statistically monitor how you are using the Site to help us improve our offerings, or to determine the popularity of certain content.
Action tags,” also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Site, including e-mail sent on our behalf, may contain action tags.
We may also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other statistical data involving the use of the Site. This information may be used to analyze trends, to administer the Site, to monitor the use of the Site, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes such as personalizing your experience on the Site and evaluating and improving the Site in general.
3. DOES MONOCL COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?
We are committed to protecting the privacy of children. The Site is not designed for or directed to children under the age of 13. We do not collect personally identifiable information from any person we actually know is under the age of 13.
4. WHAT DOES MONOCL DO WITH THE INFORMATION IT COLLECTS?
We will use your personally identifiable information to the extent that the law allows us to do so. Pursuant to the GDPR, legal bases for our processing your personally identifiable information may include (without limitation):
- (a) where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;
- (b) where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Site, Support Calls, or otherwise); and/or
- (c) where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing or marketing the Site and your interests or fundamental rights and freedoms do not override those legitimate interests.
We use the information collected to provide the Site to you, to provide a Webinar that you sign up for or participate in, to help us understand who uses the Site and the Monocl Platform (and how), for internal operations such as operating and improving the Site and the Monocl Platform, to contact you for customer service and for Support Call purposes, to facilitate our marketing activities, and, unless you opt out (to the extent permitted by applicable law), so that we and third parties acting on our behalf can contact you about products and services that may be of interest to you. In particular, unless you opt out (to the extent permitted by applicable law), we and third parties acting on our behalf may send you electronic newsletters, contact you about the Site, the Monocl Platform, products, services, information and news that may be of interest to you, and provide you with targeted feedback. Some of this information may be tailored to you based on your usage of the Site. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email to: email@example.com.
If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personally identifiable information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference.
We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Site. We may link some of this information to personally identifiable information for internal purposes or to improve your experience with the Site.
5. WHEN DOES MONOCL DISCLOSE INFORMATION TO THIRD PARTIES?
Laws and Legal Rights.
We may disclose your information (including personally identifiable information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose personally identifiable information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Site, the Monocl Platform, or the general public.
Analytics and Advertisement Targeting Service Providers.
When users use our Site, third-party analytics and advertisement targeting service providers may directly collect personally identifiable and non-personally identifiable information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect personally identifiable and non-personally identifiable information may include providers of advertisement targeting services and providers of analytics products or services (including vendors, analytics and advertisement targeting service providers, and website tracking services). Please note in particular that the Site uses Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at https://www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.
We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products, such as hosting and maintaining the Site, providing fraud screening, and developing applications for the Site. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Site, including your personally identifiable information.
Sale of Business.
Our Site may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Site. A link to a third party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each and every such website and service.
We use reasonable efforts designed to ensure that the information we have collected about you is secure. In order to prevent unauthorized access to or unauthorized alteration, disclosure or destruction of data, we have put in place commercially reasonable physical, electronic and managerial procedures designed to safeguard and secure the information we collect. Such measures include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personally identifiable information.
8. COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?
9. FOR HOW LONG WILL MY PERSONALLY IDENTIFIABLE INFORMATION BE KEPT?
We will only retain your personally identifiable information for as long as necessary to fulfill the purposes for which we collected it.
To determine the appropriate retention period for personally identifiable information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personally identifiable information and whether we can achieve those purposes through other means, and the applicable legal requirements.
10. WHAT CHOICES DO I HAVE REGARDING MY PERSONALLY IDENTIFIABLE INFORMATION?
Under certain circumstances and in compliance with the GDPR, you may have the right to:
Request access to your personally identifiable information (commonly known as ‘subject access request’). This enables you to receive a copy of the personally identifiable information we hold about you and to check that we are lawfully processing it;
Request correction of the personally identifiable information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
Request erasure of your personally identifiable information. This enables you to ask us to delete or remove your personally identifiable information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your personally identifiable information in certain circumstances;
Object to processing of your personally identifiable information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;
Request the restriction of processing of your personally identifiable information. This enables you to ask us to suspend the processing of your personally identifiable information, for example, if you want us to establish its accuracy or the reason for processing it;
Request the transfer of your personally identifiable information to another party; and
Lodge a complaint with the relevant supervisory authority (as defined in the GDPR). If you have any complaints about the way we process your personally identifiable information, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.
If you want to review, verify, correct or request erasure of your personally identifiable information, object to the processing of your personally identifiable information, or request that we transfer a copy of your personally identifiable information to another party, please contact firstname.lastname@example.org.
You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personally identifiable information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all personally identifiable information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.
DO NOT TRACK
The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.
12. WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?
By postal mail or courier:
Attn: Data Protection Officer
426 77 Västra Frölunda
13. SPECIAL NOTICE FOR CALIFORNIA RESIDENTS.
This Section 13 shall apply only to the extent that we are regulated as a business (as defined in the California Consumer Privacy Act of 2018 (collectively with any regulations promulgated thereunder, the “CCPA”)) under the CCPA. This Section 13 shall apply to you only if you are a California resident.
As used in this Section 13, “sell” (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information (as defined below) to another business or a third party for monetary or other valuable consideration.
“Selling” does not include (i) disclosing consumer information to a third party at your direction, provided the third party does not sell the consumer information except in accordance with the CCPA, (ii) where you intentionally interact with a third party through the Site, provided the third party does not also sell the consumer information, (iii) using or sharing your consumer information with a service provider as necessary to perform business purposes, provided that such service provider provides its services on Monocl’s behalf and provided that the service provider does not further collect, sell or use the consumer information except as necessary to perform the business purpose, or (iv) transfers of your consumer information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Monocl, provided that information is used or shared consistently with the CCPA.
|Category||Examples||Business or commercial purposes for which we collect, use, and sell consumer information|
|A. Identifiers.||Name, e-mail address, job title, company, Support chat transcripts, city, country, continent, postal address, IP address, online identifier, company size, department, prospective use-cases, interests, telephone number, and any other information you may choose to share with us.||
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||Name, telephone number, postal address, and job title.||
|C. Internet or other similar network activity.||IP address, search history, user log-in information, language, internet service provider, demographic information, browser types, browser system, unique device identifiers, email client, device types, requested URL, referring URL, traffic source, browser language, the pages you view, content you engage with, the date and time of your visit, location (city, country, continent), the duration of your visit, operating system, domain names, and statistical data involving the use of the Site.||
|D. Professional or employment-related information.||Job title.||
- 13.3.1 Outside Contractors; and
- 13.3.2 Corporate Affiliates.
13.5 California Residents’ Rights and Choices: The CCPA provides California residents with specific rights regarding their consumer information. This Section 13.5 describes your CCPA rights (to the extent applicable to you) and explains how to exercise those rights.
- 13.5.1 Access to Specific Information and Data Portability Rights: You may have the right to request that Monocl disclose certain information to you about our collection and use of your consumer information over the past 12 months. Once we receive and confirm your verifiable consumer request (in the manner described in Section 13.6 below), to the extent required by the CCPA, we will disclose to you:
- 126.96.36.199 The categories of consumer information we collected about you.
- 188.8.131.52 The categories of sources for the consumer information we collected about you.
- 184.108.40.206 Our business or commercial purpose for collecting that consumer information.
- 220.127.116.11 The categories of third parties with whom we share that consumer information.
- 18.104.22.168 The specific pieces of consumer information we collected about you (also called a data portability request).
- 22.214.171.124 If we disclosed your consumer information for a business purpose, a list disclosing disclosures for a business purpose, identifying the consumer information categories that each category of recipient obtained.
We will not provide the foregoing access and data portability rights for B2B consumer information prior to January 1, 2021.
13.5.2 Deletion Request Rights: You have the right to request that Monocl delete any of your consumer information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you (if you are a California resident) in the manner described in Section 13.6 below (“verifiable consumer request”), we will delete (and direct our service providers to delete) your consumer information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- 126.96.36.199 Complete the transaction for which we collected the consumer information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- 188.8.131.52 Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- 184.108.40.206 Debug products or services to identify and repair errors that impair existing intended functionality.
- 220.127.116.11 Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- 18.104.22.168 Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- 22.214.171.124 Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- 126.96.36.199 Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- 188.8.131.52 Comply with a legal obligation.
- 184.108.40.206 Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will not provide the foregoing deletion rights for B2B consumer information prior to January 1, 2021.
13.6 Exercising Access, Data Portability, and Deletion Rights:
- 13.6.1 To exercise the access, data portability, and deletion rights described in Section 13.5 above, please submit a verifiable consumer request to us by either: (1) calling us at 888-211-9007; (2) visiting link; or (3) contacting us in accordance with Section 12. Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable consumer request related to your consumer information. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected consumer information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with consumer information if we cannot verify your identity or authority to make the request and confirm the consumer information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use consumer information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. In the event you make a request under this Section 13, we may take various approaches to verify your identity depending on the nature of your request. These approaches may include initiating video conferencing or telephone calls with you or reaching out to by email or otherwise to ask you questions pertaining to the information we have about you.
- 13.6.2 We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your consumer information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.
13.7 Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:
- 13.7.1 Denying you goods or services.
- 13.7.2 Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- 13.7.3 Providing you a different level or quality of goods or services.
- 13.7.4 Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.