ANVYL, INC. PRIVACY POLICY

Effective date: July 18, 2018

This Privacy Policy tells you how we collect, use and share information including Personal Information we collect on our website www.anvyl.com and any related Anvyl mobile application (collectively the “Site”) effective as of the date posted above. By using the Site and submitting information you agree that we may use and disclose your information according to the terms of this Policy. “Personal Information” , is any information that enables us to identify you, directly or indirectly, such as your email address, name, shipping and billing address, telephone number, company name, credit card information, any form of identification number or one or more factors specific to your physical, physiological, mental, economic, cultural or social identity. For purposes of the EU General Data Protection Regulation 2016/679 (the “GDPR”), the data controller is Anvyl, Inc., whose registered office is at 335 Madison Ave., New York, NY 10017.

Information collected and how it is used

We automatically collect information when you visit the Site including information about your device such as its IP address, browser type and version, operating system, or device type, and statistics about how you use the Site, such as the pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We may ask mobile users whether they will permit us to collect information about their location. We collect location information only from mobile users who have agreed to provide that information. We do not treat this information as Personal Information, except where the information can identify you when associated with other Personal Information we hold or where we are required to do so under applicable law.

You are permitted to view limited portions of our Site without providing any information. In order to engage in our services and to view restricted areas of the Site you are required to register. We collect information that you submit when visiting the site including registration information (your name, email or postal address, company affiliation, telephone number and user name and password), contact information if you or contact us with an inquiry (your name, email address, company name, telephone number), or payment card information if you make a payment through the Site (name, billing and shipping address, card information, email and telephone number). Users who register to use our Services may be asked to provide references which may include Personal Information relating to third parties. Please insure that those third parties have consented to the use of their Personal Information by Anvyl for the purpose of confirming your identity or the identity of your company. When you engage our services you agree that the information that you provide about yourself and your affiliated company is accurate, complete and current.

We use the collected information according to the terms of this Privacy policy and our Terms of Website Use in effect at the time of our use for our general commercial purposes such as to improve our Site, grow our business and to offer our own, our affiliates’ or third-party products or services that we think you may find of interest. When you engage our services we use your information to make introductions to counterparties that may be interested in contacting you about engaging in a business transaction with you and to perform our services to you. We also use your contact information to respond to your inquiries or to provide information on products or services to you. We will process your Personal Information where (1) you have provided your consent which can be withdrawn at any time, (2) where the processing is necessary for the performance of a contract to which you are a party (for example, we will share your Personal Information with others with whom you have entered into a transaction), (3) where we are required by law, (4) where processing is required to protect your vital interests or those of another person, or (5) where the processing is necessary for the purposes of our legitimate commercial interests, except where such interest are overridden by your rights and interests.

We may use the Personal Information you give us for our legitimate commercial interests including, among other things:

We may use the Personal Information we collect in either an identifiable or an anonymized form (independent of any personal identifiers):

Cookie Policy

We use cookies and similar technology to collect aggregate (non-personal) information about Site usage by all of our visitors and to help us remember you and your preferences when you revisit the Site. These cookies may stay on your browser into the future until they expire or you delete them. We also use technology to remember registered users when they return to the Site. These cookies usually are erased when you close your browser window. Further general information about cookies and how they work is available at www.allaboutcookies.org.

The cookies we use on our Site include:

  1. Session cookies: These temporary cookies expire and are automatically erased whenever you close your browser window. We use session cookies to grant our users access to content and to enable actions they must be logged in to do.
  2. Persistent cookies: These usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve the Site for our customers. For example, we may use a persistent cookie to associate you with your user account or to remember that your choices on the Site, but this only works when cookies on our Site are enabled. We do not use technology that recognizes a “do not track” signal from your web browser.
  3. Third party cookies: We allow limited third parties to place cookies through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website. We may also permit third party service providers to place cookies through our Site to perform analytic or marketing functions. For example, we use Google Analytics to assist in our marketing and Site management efforts. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.

Your use of our Site will be deemed to be your consent to the placement of cookies on your computer or another device. If you prefer not to receive cookies through our Site, you can set your browser to either reject all cookies, to allow only “trusted” websites to set them, or to accept only those cookies from those sites you are currently on. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Site and use it.

If you refuse cookies, this will limit system performance and may even cause certain features of the Site to malfunction or not to work at all.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Third Party Cookies

Cookie Source / Cookie Name Purpose
Google Analytics We utilize Google Analytics to analyze usage patterns of the Site. Google Analytics generates cookies to capture information about your use of the Site which Google uses to compile reports on website activity for us and to provide other related services.
Google may use a portion of your IP address to identify their cookie, but this will not be associated with any other data held by Google.Please see the following link for an overview of privacy at Google:
https://support.google.com/analytics/answer/6004245Please visit the Google Analytics opt-out browser to learn how to opt-out of Google cookies:
https://tools.google.com/dlpage/gaoptout
Intercom We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom’s use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience.

For more information on the privacy practices of Intercom, please visit: https://www.intercom.com/terms-and-policies#privacy.

Intercom’s services are governed by Intercom’s terms of use which can be found at: https://www.intercom.com/terms-and-policies#terms.

If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.

Segment We use Segment to understand user behavior in order to measure how users are interacting with what we’ve already built so that we may refine it, as well as to better serve our customers by understanding what features they use and how frequently when interacting with the site.

These cookies track information about visits to the Websites so that we can make improvements and report our performance. For example: analyze visitor and user behavior so as to provide more relevant content or suggest certain activities. They collect information about how visitors use the Websites, which site the user came from, the number of each user’s visits and how long a user stays on the Websites. We might also use analytics cookies to test new pages or features to see how users react to them.

For more information on the privacy practices of Segment, please visit:
https://segment.com/docs/legal/privacy/

Segment’s services are governed by Segment’s terms of service which can be found at:
https://segment.com/docs/legal/terms/

 

Children’s Privacy

This Site is not designed nor intended to be attractive to use by children under the age of 13. We do not knowingly collect information from children under the age of 13. If you are under 13 please do not submit any information to us.

Accessing your information and your choices

You can update, amend or delete your information at any time by signing in to your account.
You can choose not to receive marketing emails from us by “unsubscribing” using the instructions in any email you receive from us. This will not stop us from sending emails about your account or your transactions with us.
You can choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies performance of the Site may be impaired and certain features may not function at all. You can opt out of receiving targeting advertisements at www.aboutads.info, www.networkadvertising.org/choices, or www.youronlinechoices.eu (Europe only).

Subject to any legislation which might, from time to time, oblige us to store the Personal Information for a certain period of time, we will respect your wishes to correct inaccurate Personal Information. Otherwise, we will hold your Personal Information for as long as we believe it will help us to achieve our aims as detailed in this Privacy Policy.

You can ask us whether we are keeping Personal Information about you and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.

Sharing your information

We may reveal information about you to unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.); (4) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets); (5) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing transactions, etc.) and who are required by agreement to process information in accordance with applicable law; or (6) as otherwise described in this Privacy Policy.

We may share your information with our affiliated companies without restriction.

With your permission we may share your information with third parties that they may use for their marketing purposes.

Where you use our Site to enter into a transaction or proposed transaction with another individual or business we provide your Personal Information to that other party in order to facilitate the transaction or the correspondence you have requested. These parties may use your Personal Information for their own purposes including marketing purposes. They may have their own privacy practices that may be inconsistent with Anvyl’s practices. Please read such applicable privacy policies, as we are not responsible for the processing of your Personal Information by such third parties.

We may disclose your non-private, aggregated, or otherwise non-Personal Information, such as usage statistics of our Products, to our affiliates and third parties.

Your California Privacy Rights

California residents are permitted by California law to request information about the manner in which we share certain categories of information with others for their marketing purposes.

We do not share your personal information with third parties for their direct marketing use unless we have your permission. To withdraw permission previously granted please email us at rodney@anvyl.com. Once we receive your instruction we will cease sharing your information, but this will not affect previously shared information.

Your European privacy rights

For individuals within the EEA only. Under the GDPR, in certain circumstances, you have the right to: (a) request access to any Personal Information we hold about you and related information, (b) obtain without undue delay the rectification of any inaccurate Personal Information, (c) request that your Personal Information is deleted provided the Personal Information is not required by anvyl.com for compliance with a legal obligation under European or Member State law or for the establishment, exercise or defense of a legal claim, (d) prevent or restrict processing of your Personal Information, except to the extent processing is required for the establishment, exercise or defense of legal claims; and (e) request transfer of your Personal Information directly to a third party where this is technically feasible.

In addition, where you believe that Anvyl has not complied with its obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority.

Security

We use reasonable technical, administrative and physical measures to protect information contained in our system against misuse, loss or alteration. Except as specified in this Privacy Policy, we use commercially reasonable efforts to limit access to your Personal Information to the employees, officers, third-party contractors, and strategic partners of Anvyl who need the Personal Information in order to perform their duties. We may use standard SSL technology to protect information being transferred to our site, but no method of electronic transmission or storage is 100% secure. If we receive instructions using your log-in information we will consider that you have authorized the instructions.

Data Processing and Cross-Border Data Transfers

Our Site is maintained on servers located in the United States, and personal information submitted is stored on our servicers in the United States. If you are visiting our Site from outside the United States, please be advised that your information is transferred to our U.S. servers. Disclosing your personal information to us pursuant to this Privacy Policy is at your own risk. We strive to comply with laws of jurisdictions in which we maintain operations but we make no representations that the practices described in this Privacy Policy are compliant with laws outside those jurisdictions that apply to the collection, security, use and disclosure of personal information. By using this Site and by providing any Personal Information to the Site, all users, including without limitation users in Canada and the European Union, fully understand and unambiguously consent to the collection and processing of such Personal Information in the United States.

Due to the nature of our business and to enable us to offer services worldwide, your Personal Information may be transferred to and held by merchants or sellers in any country in the world. By using this Site and by providing any Personal Information to the Site, all users, including without limitation users in Canada and the European Union, fully understand and unambiguously consent to the collection and processing of such Personal Information by such third parties.

Links to other sites

We may permit others to link to this Site or to post a link to their site on ours. We do not endorse these sites and are not responsible for other sites or their privacy practices. Please read their privacy policies before submitting information.

Changes to the Privacy Policy

As we grow and change we may amend this Privacy Policy. The Policy in effect at the time you use the Site governs how we may use your information. If we make material changes we will post the revised Policy and the revised effective date on this Site. Please check back here from time to time to review any changes.

Contacting us

This Site is owned and operated by Anvyl, Inc. You can contact us at Anvyl, 335 Madison Ave., New York, NY 10017, (929) 333-5069, support@anvyl.com.