EFFECTIVE DATE: February 22, 2021
This Privacy Policy (“Policy”) describes how Soteri LLC (“we,” “us,” or “our”) collects, uses, and discloses information that we obtain about your use of the Soteri.io website (the “Site”) and Soteri products and hosted services, collectively the “Service.”
We store your information in the United States. By using or downloading the Service you agree that your personal information may be transferred to and stored in the United States and handled as described in this Policy.
The Information We Collect About You.We collect information directly from you, from devices and third party services you connect, as well as automatically through your use of our Service. If you purchase a Service that will be hosted on your server, Soteri does not collect any information from the device it is installed upon.
When You Create, Update, or add information to Your Profile.When you register to use the Service, we collect the personal information you provide us, including your name and email address. We may also collect information that you provide to Atlassian and which Atlassian sends to us on your behalf.
AND
We collect additional information from Devices you connect to the Service:
· When You Contact Us.When you contact Soteri directly, such as when you contact our Customer Support team, we will receive the contents of your message or any attachments you may send to us, as well as any additional information you choose to provide.
· Third Party Analytics.We use automated devices and applications, such as Google Analytics, to evaluate usage of our Service. We also may use other analytic means to evaluate our Service. Soteri does not use any analytic software for Services that are hosted by you on your server.
How We Use Your Information
We process your information, including your personal information, for the following purposes:
· To provide our Service to you, to communicate with you about your use of our Service, to respond to your inquiries, and for other customer service purposes.
· For marketing and promotional purposes, to the extent permitted by law and, where required, with your consent. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services on third party websites. You can opt-out of receiving marketing at any time as described below.
· To better understand how users access and use our Service, both on an aggregated and individualized basis, in order to improve our Service and respond to user desires and preferences, and for other analytical purposes.
· To administer surveys and questionnaires.
· To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
· Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our End User License Agreement or this Privacy Policy.
How We Share Your Information.We may share your information, including personal information, as follows:
· With Your Consent.With your prior consent, we may share information from the Service with other third-party partners, including your personal information and data collected from your devices.
· Aggregate and De-Identified Information.We may share aggregate or de-identified information—so that it cannot reasonably be used to identify an individual—with third parties for marketing, advertising, research or similar purposes.
· We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
· Service Providers.We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf, such as providers of hosting, email communication, customer support services, analytics, marketing, and advertising,based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures.
· Business Transfers.If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding or reorganization, we will give affected users notice before transferring any personal information to a new entity.
· In Response to Legal Process.We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person.
· To Protect Us and Others.We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which Soteri is involved.
Privacy Shield Information For EU and Swiss Individuals
Soteri complies with the EU-U.S. Privacy Shield Framework and the Swiss-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 and Switzerland to the United States pursuant to the Privacy Shield. Soteri 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 http://www.privacyshield.gov.
In compliance with the Privacy Shield Principles, Soteri commits to resolve complaints about your privacy and our collection or use of your personal information pursuant to the Privacy Shield. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Soteri at the contact address below.
Soteri LLC
8726 S Sepulveda
Blvd, Ste D #322,
Los Angeles, California 90045
Soteri has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS, an international alternative dispute resolution provider. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shieldfor more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
The Federal Trade Commission has jurisdiction with enforcement authority over Soteri’s compliance with the Privacy Shield.
The Privacy Shield Principles describe Soteri’s accountability for personal data that it subsequently transfers to a third-party agent. Under the Privacy Shield Principles, Soteri shall remain liable if third party agents process the personal information in a manner inconsistent with the Privacy Shield Principles, unless Soteri proves it is not responsible for the event giving rise to the damage.
Note that Soteri may be required to release the personal data of EU and Swiss individuals whose data is pursuant to the Privacy Shield in response to legal requests from public authorities including to meet national security and law enforcement requirements.
Cookies
Cookies are small text files stored on your device and used by web browsers to deliver personalized content and remember logins and account settings. In addition to improving user experience, we use cookies and similar technologies for analytic and advertising purposes. You can manage your cookies locally by adjusting your browser settings, or you can opt-out of targeted advertising through cookies by visiting networkadvertising.org/choicesor aboutads.info/choices. Because there is not yet a common understanding of how to interpret Do Not Track signals, we are unable to respond to Do Not Track requests from browsers, however we are monitoring for updates and will revisit this policy once a common standard is established.
Third-Party Links
Our Service may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites. Specifically, use of the Service will require a subscription to services provided by Atlassian, and the access and use of Atlassian services is not governed by this policy.
Security of My Personal Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access to and Deleting My Personal Information
We acknowledge the right of EU and Swiss individuals to access their personal data pursuant to the Privacy Shield. You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Service for a period of time.
We store information associated with your account until your account is deleted. You can delete your account at any time by contacting Customer Support at [EMAIL]. Please note that it may take a bit of time to delete your account information, and we may preserve it for legal reasons or to prevent harm, including as described in the How Information Is Shared section.
What Choices Do I Have Regarding Promotional Emails?
We may send periodic promotional emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. We may still send you emails about your account or any services you have requested or received from us.
Users Under 18
Our services are not designed for users under 18. If we discover that a user under 18 has provided us with personal information, we will delete such information from our systems.
GDPR – Rights For EEA Users and Soteri’s Capabilities for Worldwide Users
What Rights Do I Have?Individuals located in the European Economic Area (EEA) have certain rights in respect of your personal information and Soteri will provide these capabilities to all our worldwide users, including:
· the right of access to your personal data;
· the right to correct or rectify any inaccurate personal data;
· the right to restrict or oppose processing of personal data;
· the right to erase your personal data; and
· the right to receive your personal data in a portable format.
We rely on your consent as a lawful basis processing personal data for the following purposes:
· initial collection of personal data through the Service;
· providing you with marketing or promotional communications. You may opt out of such communications at any time by clicking the “unsubscribe” link found within Soteri email updates and changing your contact preferences.
We process personal data in order to perform our contract with you.
Additionally, we process personal data based on our “legitimate interests” in providing you the Service as described in the section “How We Use Your Information”, including:
· To enable the Service to function as expected; and
· To communicate with you in response to customer service inquiries, to deliver non-promotional, service-related emails, or to administer surveys and questionnaires.
In some cases, Soteri may process personal information pursuant to a legal obligation or to protect your vital interests or those of another person.
How May I Exercise My Individual Rights?Soteri users located worldwide may access and update their personal information as follows:
· Account holders may access and update personal information through their account settings in Atlassian;
· Account holders may exercise their rights to data deletion and data portability by contacting Soteri’s Data Controller Representative at privacy.Soteri.io.
· Soteri does not retain any personal information from users who do not evaluate or purchase Services.
Please note that Soteri may request additional information from you to verify your identity before we disclose any personal or account information.
Contact Us
If you have questions about our privacy practices, please contact us at privacy@Soteri.io.
Soteri LLC
8726 S Sepulveda
Blvd, Ste D #322,
Los Angeles, California 90045
If you are an EEA customer and are unable to reach Soteri at the contact information provided above regarding your issue, you have the right to contact your local Data Protection Authority.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Service. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change.