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Euclid Privacy Statement

Euclid Privacy Statement (last updated December 15, 2022)

Euclid Technology Solutions (“Euclid,” “we,” “us,” “our,” or the “Company”) is committed to protecting the privacy of individuals who visit our website (“Visitors”), individuals who use our Services as defined below (“Customers”), and individuals who register to attend Euclid's events (“Attendees”). This Privacy Statement describes Euclid’s privacy practices in relation to the use of the Company’s Websites and the related applications, services, and programs offered by Euclid (collectively, the “Services”), as well as individuals’ choices regarding use, access and correction of personal information.

If you have questions or complaints regarding Euclid’s Privacy Statement or associated practices, please contact us at Compliance.PC9@fullsteam.com.

If you are a resident of the State of California, please be sure to read section 12: California Residents - Your Privacy Rights below to understand additional rights you may have pursuant to California Civil Code Section 1798.83 and the California Consumer Privacy Act of 2018.

Euclid is subject to the investigatory and enforcement powers of the Federal Trade Commission (the “FTC”). Euclid 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 transferred from the European Union to the United States. Euclid has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. If you are an EU resident, please see section 13: EU Data Subject Rights for additional rights regarding your personal information.

1. Websites covered

This Privacy Statement covers the information practices, including how Euclid collects, uses, shares and secures the personal information you provide the Company's Website (euclidtechnology.com). 

Euclid's Website has links to other non-Euclid Websites. The information practices or the content of such other Websites is governed by the privacy statements of such other Websites. Euclid encourages you to review the privacy statements of other Websites to understand their information practices.

2. Information collected

When expressing an interest in obtaining additional information about the Services, or registering to use the Website or other Services, or registering for an event, Euclid requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Services or registering for an event, Euclid may also require you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Services (“Billing Information”). Euclid may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). When Visitors apply for a job with the Company, Euclid may also require you to submit additional personal information as well as a resume (“Applicant Information”). Required Contact Information, Billing Information, Applicant Information, Optional Information and any other information you submit to Euclid to or through the Services are referred to collectively as “Data.”

As you navigate our Website, Euclid may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Website Navigational Information”). Website Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the our Website (such as the Web pages viewed and the links clicked).

Through our “add contacts” feature on the Euclid Support Website, we may also collect information such as the name, address, phone number or email address of contacts that you choose to share with us.  When you provide us with personal information about your contacts, we will only use this information for the specific reason for which it is provided, such as to add new records to your Euclid support account.

3. Use of information collected

The Company uses Data about Euclid Customers to perform the services requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Services.

The Company also uses Data about Euclid Attendees to plan and host corporate events, host online forums and social networks in which event Attendees may participate, and to populate online profiles for Attendees on the Company’s Websites. Additional information on the Company’s privacy practices with respect to Data about Euclid Attendees may be found in additional privacy statements on the event Websites, as the case may be.

The Company may also use Data about Euclid Customers and Attendees for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding the Company, our Services and promotional information.

Euclid may also receive information about Customers and Attendees from other sources, including third parties from whom we have purchased data, and combine this information with Data we already have about you.  This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide products and services that may be of interest to you.

Euclid uses credit card information solely to collect payment from Customers and Attendees.

Euclid uses Website Navigational Information to operate and improve the Company’s Websites. The Company may also use Website Navigational Information alone or in combination with Data about Euclid Customers and Data about Euclid Attendees to provide personalized information about the Company. For additional information about the use of Website Navigational Information, please see section 4. Website Navigational Information below.

Euclid uses services offered by Google and Google Analytics to collect, aggregate and analyze data in order to better understand how the site is used. Euclid uses these cookies to collect anonymous and aggregated data for a limited time. The data is used, for example, to monitor and analyze site use, improve its functions and more accurately choose content and graphic design, in order to meet visitors' expectations.

Information on how Google Analytics is used and its privacy policy are available on this link.

 

We rely on the following legal grounds to process your personal information:

 

Consent. We may use your personal data as described in this Privacy Policy subject to your consent.

 

Performance of a contract. We may need to collect and use your personal information and the personal information of your customers, as applicable, to perform our contractual obligations. When we process personal data on behalf of third parties, we do so pursuant to agreements with such third parties.

 

Legitimate Interests. We may use your personal information for our legitimate interests to provide our services and to improve our services and the content on our application. We process information on behalf of third parties who have legitimate interests in operating their businesses. We may use technical information as described in this Privacy Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.

 

4. Website Navigational Information

Cookies, Web Beacons and IP Addresses

Euclid uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Website (“Website Navigational Information”). As described more fully below, we use these cookies or similar technologies to analyze trends, administer the Website and Services, track users’ movements around our Website and Services, and provide personalize content.  This section describes the types of Website Navigational Information used on the Company’s Websites and Services, and how this information may be used.

Cookies
Euclid uses cookies to make interactions with the Company’s Website easy and meaningful. When you visit one of our Websites, Euclid’s servers send a cookie to your computer or device. Standing alone, cookies do not personally identify you; they merely recognize your Web browser. Unless you choose to identify yourself to Euclid, either by opening an account or filling out a Web form (such as a “Schedule a Demo”) or have previously identified yourself to Euclid, you remain anonymous to us.

Euclid uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer or device 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. 

The following sets out how Euclid.com uses different categories of cookies and your options for managing cookies’ settings:

Type of Cookies

Description

Managing Settings

Required cookies

Required cookies enable you to navigate the Company’s Website and use its features, such as accessing secure areas of the Websites and using Euclid Services.
If you have chosen to identify yourself to Euclid, the Company may place on your browser cookies containing a unique identifier. These cookies allow the Company to uniquely identify you when you are logged into the Websites and Services and to process your online transactions and requests.

Because required cookies are essential to operate the Company’s Websites and the Services, there is no option to opt out of these cookies.

Functional cookies

Functional cookies allow Euclid's Website and Services to remember information you have entered or choices you make (such as your language or your region) and provide enhanced, more personal features.  These cookies also enable you to optimize your use of Euclid’s Website and Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.

Functional cookies may also be used to improve how the Company's Websites and Services function and perform, to enhance and customize your interactions with the Company, and to help us provide you with more relevant messages, including marketing communications. These cookies collect information about how Visitors use our Websites and Services, including which pages visitors go to most often and if they receive error messages from certain pages.

Euclid may use its own technology (e.g., ClearVantage) or third parties to track and analyze usage and volume statistical information from Visitors, Attendees, and Customers, to provide enhanced interactions and more relevant communications, and to track the performance of the Company's advertisements.

Euclid may also utilize HTML5 local storage for these purposes.HTML local storage is different from browser cookies because of the amount of, type of, and how data is stored.

To manage the use of functionality cookies on this Website, or to opt out of their use, click "Cookie Settings" in the footer of this page. Note that opting out may impact the functionality you receive when using Euclid's Website and Services.

Performance cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

To manage the use of performance cookies on this Website, or to opt out of their use, click "Cookie Settings" in the footer of this page. Note that opting out may impact the functionality you receive when using Euclid's Website and Services.

Targeting  cookies

Euclid sometimes uses cookies delivered by third parties to determine how you learned about Euclid and to display content or Euclid products and services that we think may interest you. Euclid does not provide your personal information or your browsing data with third-parties. However, information provided by third parties, such as the ad-word that was clicked that led you to our site, may be re-associated with personal information to create a more comprehensive profile of website Visitors, Customers and Attendees. 

 

Euclid does not utilize third-party advertising networks on our site. Such networks collect IP addresses and other information from Web beacons and utilize it to track user activity across websites. 

To manage the use of targeting and advertising cookies on this Website, or to opt out of their use, click "Cookie Settings" in the footer of this page. Note that opting out may impact the functionality you receive when using Euclid's Website and Services.

 

In particular, Euclid uses the following cookies:

Cookie name

Purpose

Type of cookie

Expiry   

.ASPXANONYMOUS

Allows connection without authentication

Required

At the end of the session

__RequestVerificationToken

Anti-forgery cookie that blocks the transmission of unauthorized data to the website ("Cross-Site Request Forgery").

Required

At the end of the session

dnn_IsMobile

Identifies the type of connected device

Required

At the end of the session

language

Identifies the user's language

Required

At the end of the session

.DOTNETNUKE

Identifies the user if authenticated on the website

Required

At the end of the session or after 20 hours if the "Remember me" option is activated

EU_Optin

Identifies whether the user has read and consented to Euclid's cookie policy

Required

1 year

sessionID

This is a unique identifier for a logged in user

Required

At the end of the session

_utma, _utmb,_utmc,_utmt,_utmz

Used by Google Analytics to collect, aggregate and analyze data in order to better understand how the site is used and improve site performance.

Performance

At the end of the session

Any other cookies generated by www.euclidtechnology.com and not present in this table are functional or targeting cookies.

Third party cookies

Euclid uses services offered by Google and Google Analytics to collect, aggregate and analyze data in order to better understand how the site is used. Euclid uses these cookies to collect anonymous and aggregated data for a limited time. The data is used, for example, to monitor and analyze site use, improve its functions and more accurately choose content and graphic design, in order to meet visitors' expectations.

Web Beacons
Euclid uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Websites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Website or Service tied to the Web beacon, and a description of a Website or Service tied to the Web beacon. For example, Euclid may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Websites. Euclid uses Web beacons to operate and improve the Company’s Websites, Services and email communications.

Log Files, IP Addresses, URLs and Other Data
As is true of most Websites, we gather certain information automatically to analyze trends in the aggregate and administer our Websites and Services.  This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use the Company’s Websites and Services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our Website. This information is used to analyze overall trends, to help us improve our Websites and Services, to track and aggregate non-personal information, and to provide the Websites and Services. For example, Euclid uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Websites. Euclid also collects IP addresses from Customers when they log into the Services as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features.

Social Media Features and Single Sign-on
The Company’s Websites may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect your IP address and which page you are visiting on the Company’s Website and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on the Company’s Website to a profile page of yours that is provided by a third party social media network in order to share with others within your network. Social Media Features are either hosted by a third-party or hosted directly on the Company’s Website. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features. Euclid also allows you to log in to certain of our Websites and Services using sign-in services such as Facebook Connect. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form.

Do Not Track
Currently, various browsers — including Internet Explorer, Firefox, and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Websites’ visited by the user about the user's browser DNT preference setting. Euclid does not currently commit to responding to browsers' DNT signals with respect to the Company's Websites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Euclid takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

5. Public forums, refer a contact, and customer testimonials

Euclid may provide bulletin boards, blogs, or chat rooms on the Company’s Websites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Euclid is not responsible for the personal information you choose to submit in these forums.

Customers and Visitors may elect to use the Company’s referral program to inform contacts about the Company’s Websites and Services. When using the referral program, the Company requests the contact’s name and email address. Euclid will automatically send the contact a one–time email inviting him or her to visit the Company’s Websites. Euclid does not store this information.

Euclid posts a list of Customers and testimonials on the Company’s Websites that contain information such as Customer names and titles. Euclid obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.

6. Sharing of information collected

It is your choice of whether or not you share information with Euclid and what information you share. You also have complete control over what, if any, of your personal information is shared with third parties. Your explicit opt-In is required before Euclid shares your personal information with any third parties. For EU Subjects, please see section 13. EU Data Subject Rights for additional rights and protections regarding the sharing of your information.

Additional details regarding sharing of information with third parties is below.

Service Providers
Unless described in this Privacy Statement, Euclid does not share, sell, rent, or trade any information with third parties for their promotional purposes.

Business Partners
From time to time, Euclid may partner with other companies to jointly offer products, services, or programs (such as webinars or downloadable content). If you purchase, specifically express interest in, or register for a jointly–offered product, service, or program from or through Euclid, the Company may share Data about Euclid Customers collected in connection with your purchase or expression of interest with our partner(s). You will be notified prior to purchasing a jointly offered product, service or program if your information will be shared with a business partner and exactly what information will be shared. You will need to explicitly provide consent for sharing information prior to completing the transaction. Euclid does not control our business partners’ use of the Data about Euclid Customers that we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.

Conference Sponsors

Euclid does not share Data about Euclid Conference Attendees with conference sponsors unless the attendee explicitly grants consent for us to do so during the event registration process. If you consent to sharing your information, it will be subject to the business partners’ respective privacy policy.

Third Parties
Section 4 of this Privacy Statement, Website Navigational Information, specifically addresses the information we or third parties collect through cookies and web beacons, and how you can control cookies through your Web browsers. Euclid does not share any additional information with third parties without prior written consent (unless it is Compelled Disclosure). Specifically and as detailed in Section 4, Euclid utilizes Google Analytics from Google to collect, aggregate and analyze data in order to better understand how the site is used and improve site performance. All website users must specifically opt-in to allow this data collection to occur. Website users at anytime can click on the “Cookie Settings” link at the bottom of every page on Euclid’s website to opt out of this tracking.

Billing

Euclid uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.

Compelled Disclosure
Euclid reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

7. International transfer of information collected

The Company stores Data about Euclid Customers and Data about Euclid Attendees in the United States. To facilitate Euclid’s global operations, the Company may access such information from around the world. This Privacy Statement shall apply regardless of which country the Data is accessed from by the Company.

8. Communications preferences

Euclid offers Visitors, Customers, and Attendees who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may unsubscribe here  or by contacting us using the information in the “Contacting Us" section below.

9. Correcting and updating your information

Euclid may retain your information for a period of time consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account to use our Websites or Services and for a reasonable period of time afterward. We also may retain your information during the period of time needed for Euclid to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

You may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us through the Company’s Websites and Services.  If you have registered for an account with Euclid, you may generally update your user settings, profile, organization’s settings or event registration by logging into the applicable Website or Service 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 Data associated with your account, please contact your account representative or the customer service team for the applicable Service. Residents of the EU, Iceland, Lichtenstein and Norway and certain other jurisdictions have rights to access personal data about them, and to limit use and disclosure of their personal data. Company has committed to respect those rights. Because Company personnel have limited ability to access data our customers submit to our services, if you wish to request access, to limit use, or to limit disclosure, please provide the name of the Company customer who submitted your data to our services. We will refer your request to that customer, and we will support them as needed in responding to your request.

Our Director for Compliance is responsible for our privacy programs.

To receive information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, please email compliance.pc9@fullsteam.com or request by mail addressed to:

Fullsteam Operations LLC

Attn. Compliance PC9

540 Devall Drive, Suite 301

Auburn, AL 36832

 

10. Customer Data

Euclid’s Customers may electronically submit data or information to the Services for hosting and processing purposes (“Customer Data”). Euclid will not review, share, distribute, or reference any such Customer Data except as provided in the Agreement between Euclid and Customer, or as may be required by law. The Agreement between Euclid and Customer may include but is not limited to the Subscription Agreement, Hosting Agreement, Master Agreement, Implementation Agreement, End User License Agreement, Ongoing Services Agreement, and a Work Order. In accordance with the Agreement between Euclid and Customer, Euclid may access Customer Data only for the purpose of providing the Services or preventing or addressing service or technical problems or as may be required by law. Additional information about the Company’s privacy and security practices with respect to Customer Data is available in the Security and Architecture Documentation.

Euclid acknowledges that you have the right to access your personal information.  If personal information pertaining to you as an individual has been submitted to us by a Euclid customer and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with our customer directly. Because Euclid personnel have limited ability to access data our customers submit to our Services, if you wish to make your request directly to Euclid, please provide the name of the Euclid customer who submitted your data to our Services.  We will refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe.

11. Security

Euclid uses robust security measures to protect Data about Euclid Customers and Data about Euclid Attendees. Because the Company uses the Services to maintain Data about Euclid Customers and Data about Euclid Attendees, this information, which is stored in the Services, is secured in the same manner as described in the Security and Architecture Documentation.

If we learn of a breach of our security system or processes, we may attempt to notify you electronically so that you can take appropriate protective steps. By using our websites, or providing personally identifiable information to us through them, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our websites. In the event of a breach, we may post a notice on our websites and/or send you an email at the email address you provided.

YOU MAY HAVE ADDITIONAL RIGHTS TO RECEIVE WRITTEN NOTICE OF SECURITY BREACHES UNDER APPLICABLE LAW OF YOUR JURISDICTION.

12. California Residents – Your Privacy Rights

California Information-Sharing Disclosure

(As provided by California Civil Code Section 1798.83)

A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes ("California customer") is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties' direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.

However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy statement) a policy of not disclosing customer's personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost free means to exercise that right.

Euclid does not share information with third parties for direct marketing purposes unless you affirmatively agree to such disclosure. The only time Euclid shares information with third parties for marketing purposes is at the Euclid User Group Conference: if a registrant opts to receive information from a conference sponsor, Euclid may share the registrant’s name, organization name, job title and email address with the sponsors if the registrant opted to receive information from sponsors during the registration process. Sponsors are instructed that they may only contact the opted-in registrant twice, once before the show and once after the show, unless the registrant chooses to continue to receive information from the sponsor. Please note that whenever you opt-in to receive future communications from a third party, your information will be subject to the third-party's privacy policies and practices. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as we have no control over how third parties use information. You should always review the privacy policies and practices of any party that collects your information to determine how that party will handle your information.

California customers may request further information about our compliance with this law by emailing compliance.pc9@fullsteam.com. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address.

California Do Not Track Disclosure:

Our websites do not respond to “do not track” browser signals. Depending on the browser you are using, you may be able to choose to block third party cookies or browse in a private browsing mode. Our websites are accessible even when private browsing is turned on. The information we collect is governed by this Privacy Policy.

California Consumer Additional Information under California Consumer Privacy Act of 2018 (“CCPA”)

You will not receive discriminatory treatment by us for exercising your privacy rights conferred on you by the CCPA.

You have certain additional rights regarding your personal information, pursuant to California law. These include the rights to:

  • receive a list of the categories of personal information we have collected about you;
  • receive a list of the categories of sources from which your personal information was collected;
  • receive a list of the categories of your personal information that we have disclosed for a business purpose;
  • receive a list of the categories of third parties to whom your personal information was disclosed for a business purpose;
  • know the business or commercial purpose for collecting your personal information;
  • receive a list of specific personal information we collected and for what purposes;
  • have your personal information deleted by us and direct our service providers to delete your information. However, it may be retained pursuant to an allowed exception if applicable;
  • know if personal information was collected from sources other than from you and the categories of sources from which the information was obtained; and
  • receive your personal information in a useable electronic format and transmit it to a third party (right to data portability).

Please submit your request for information or deletion of information concerning you as noted below. In order to provide you with your requested information or to delete the information which we have concerning you, we must be able to verify that you are the person requesting the information or deletion. With your request please provide at least two items of information which you have previously provided to us for us to use for verification of your identity. If this is not sufficient, we will contact you for additional means of verification.

You may designate an authorized agent to make a request for you. If your agent has a power of attorney pursuant to California Probate Code sections 4000 to 4465, please provide proof to the same. If your agent does not have a power of attorney pursuant to California Probate Code sections 4000 to 4465, we will require you to provide the authorized agent written permission to make the request, verify your own identity directly with us and require your agent to submit proof that they are authorized by you to act on your behalf.

For information concerning you or for deletion of information concerning you, please email compliance.pc9@fullsteam.com or request by mail addressed to:

 

Fullsteam Operations LLC
Attn. Compliance PC9

540 Devall Drive, Suite 301
Auburn, AL 36832

 

13. EU Data Subject Rights

If you are a resident of the EU, you have the following additional rights regarding use and access to your data (as specified under the GDPR) and are entitled to Dispute Resolution as defined below.

 Additional Rights

  • Right of access. You may request a copy of the information that we have on you by sending a request to compliance.pc9@fullsteam.com. We will reply within seven days and provide a copy of the information within thirty days.
  • Right of rectification.  You can update your information at anytime by logging into our website and updating your profile. If there is information on your profile that you cannot edit and wish to have it changed, please send an email to compliance.pc9@fullsteam.com. We will reply with seven days and correct any incorrect information within thirty days.
  • Right to be forgotten. Under certain circumstances, you can request that we delete your data from our records. The decision on whether we can delete your data is based on factors including compliance, record keeping, and other restrictions that Euclid does not have control over. To request to have your data deleted, please send an email to compliance.pc9@fullsteam.com. We will reply within seven days and accommodate your request within thirty days if we can do so. If we cannot delete or "anonymize" your data, we will provide you the reasons for doing so, and you have a right to object to our reasoning..
  • Right to restriction of processing. You can grant or remove consent for processing of your data at anytime by logging into the sight and updating your preferences.
  • Right of portability. If you would like a copy of the data that we have on you in a machine readable format (we provide it in JSON format), please send an email to compliance.pc9@fullsteam.com. We will reply within seven days and provide a copy your data in JSON format within thirty days.  
  • You have the right to opt out of (a) disclosures of your Personal Data to third parties not identified at the time of collection or subsequently authorized, and (b) uses of Personal Data for purposes materially different from those disclosed at the time of collection or subsequently authorized.

In addition to the protections and processes outlined in 6. Sharing of information collected, as an EU resident your data will not be shared with any third-party unless Euclid has a contract in place with the third-party that states a) your data may only be processed for limited and specified purposes consistent with the consent you provided; 2) The third-party will provide the same level of protection as the PrivacyShield Principles; 3) the third-party will notify Euclid if it makes a determination that it can no longer meet this obligation. The contract shall provide that when such a determination is made, the third-party controller shall cease processing or take other reasonable and appropriate steps to remediate.  

In the context of an onward transfer Euclid has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Euclid shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

 Dispute Resolution

Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Euclid Technology Solutions, LLC’s internal processes, Euclid Technology Solutions, LLC has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here:  https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/. Please note that under certain conditions as described in the dispute resolution procedure, an individual may invoke binding arbitration.

Notification of enforcement actions

Euclid will make public any relevant Privacy Shield-related sections of any compliance or assessment report submitted to the FTC if Euclid becomes subject to an FTC or court order based on non-compliance.

Privacy commitments will be kept as long as data is held

If Euclid leaves the Privacy Shield Framework, Euclid shall annually certify its commitment to apply the Principles to information received under the Privacy Shield Framework if we choose to keep such data or provide “adequate” protection for the information by another authorized means.

14. Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

15. Contacting us

Questions regarding this Privacy Statement or the information practices of the Company’s Websites and Services should be directed via email to compliance.pc9@fullsteam.com or by mail at the following address:

 

Fullsteam Operations LLC
Attn. Compliance PC9

540 Devall Drive, Suite 301
Auburn, AL 36832

 

Euclid Technology Solutions, LLC is a Limited Liability Corporation located in Bethesda, Maryland. Euclid Technology Solutions provides Association Management Software and related Implementation, Hosting and Support services to our clients, most of which are 501c organizations. You can browse our website to obtain additional information on the products and services we provide.