Last updated: December 10, 2020

The following statement outlines the privacy policy of the Outcome Chains, Inc. and its affiliated entities (hereafter collectively “OCI”). Please forward any comments or concerns you may have regarding this policy to privacy@outcomechains.com.

Introduction

This privacy policy covers the information we collect about you when you use our products, unless a different policy is displayed. We refer to all our product website (e.g. app.outcomechains.com), together with our marketing website (e.g. www.outcomechains.com) as “Websites” in this policy.

This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, do not access or use our Website or interact with any other aspect of our business.

Where we provide the Website under contract with an organization (for example your employer) that organization controls the information processed by the Website. For more information, please see Notice to End Users below.

Notice to End Users

Our Website are intended for use by organizations. Where the Website are made available to you through an organization (e.g. your employer), that organization is the administrator of the Website and is responsible for the accounts over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Website is subject to that organization’s policies. You can find your account administrator contact information in our product website, under Help -> Contact Us menu.

We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy. Please contact your organization or refer to your administrator’s organizational policies for more information.

Your administrators have near complete access to your information in Outcome Chains, including:

require you to reset your account password
restrict, suspend or terminate your access to the Outcome Chains product website
access information in and about your account
access or retain information stored as part of your account
change the email address associated with your account
change your information, including profile information
restrict your ability to edit, restrict, modify or delete information
access your messages in Outcome Chains chat rooms
access your Outcome Chains and content stored in Outcome Chains

Personal Data that we collect

“Personal Data means any information about an individual from which that person can be identified. This information you disclose to us during your access and use of our Website is referred to generally in this policy as “Personal Data “.

Personal Data you choose to provide to us

We collect information about you when you choose to enter it into the Website or otherwise provide it directly to us.

Depending on your interactions with us, that Personal Data may include:

Your name
Your job title
Your profile photo
Your employer
Email address
Phone number

You may also choose to provide Personal Data when you:

Register for access to our Website, or free resource (i.e., any form submission where you provide additional information above and beyond the information listed above)
Submit a complaint or dispute to us in conjunction with data/privacy issues outlined below in the section titled “EU-U.S. Privacy Shield and Dispute Resolution”
Email any OCI employee for assistance
Identify yourself, beyond an anonymous inquiry, via any other means, such as in-person meeting, phone or postal mail
Upload content to our Website when using our products

Data we automatically collect

When you access our Website and content online via mobile phone, computer, tablet or any other device, we automatically collect the following information:

IP address from your ISP connection or mobile carrier
Cookies and other tracking technologies (e.g., web beacons) to provide functionality and to recognize you across different Website and devices.
Your device type, browser version, screen resolution, and operating system
Pages on the Website visited
Referring websites (websites linking to the Website accessed)
Amount of time spent on each page of the Website
Search inquiries using a Website search function

Personal Data entered by other users of our Website

Other users of our Website may provide information about you when they submit content through the Website. For example, we may receive your name and email address from other users when they provide it to share an Outcome Chains with you. Also, an administrator may add your contact information in order to create an Outcome Chains account for you.

How we use your Personal Data

We use data that we collect from you:

for that which you have provided permission
as necessary to deliver the Website that you purchase or interact with
as we might be required or permitted for legal compliance or other lawful purposes

These users may include but are not limited to:

Delivering, improving, updating and enhancing the Website that we provide to you in order to ensure a positive and effective user experience with our Website.
Helping to diagnose problems should a technical issue arise with our servers
Gathering usage information when accessing our Website
Delivering customized content based upon your activities
Diagnosing potential problems to include identifying security risks, errors, or needed enhancements to our Website
Collecting aggregate statistics about the use of our Website
Tracking the number of users who visit our Website
Delivering data/search results based upon similar usage trends and analyses
Helping us to better manage content access trends, and enable the ability to add and/or to delete content based on user utilization
Understanding and analyzing how you utilize our Website and determining which products and services are most relevant to you.

In addition, we may use your Personal Data for any of the following purposes:

To respond to an inquiry from you. We have to know how to address you and look up the content to which you are entitled access.
To enable your use of our Website in accordance with any contractual obligations that we or our business partners are required to deliver
To verify your identity when you communicate with us
To contact you regarding contractual or mandatory outages, or other non-transactional requirements
To provide the Website you requested after you have consented to the collection of Personal Data to facilitate that request
To send you agreements, invoices, or modifications to the terms and conditions of our Website
To send you emails relating to any information that you have consented to receive (i.e., opted into)
To collect payments or to notify you of Website modifications/cancellations
To provide you with information where we are legally required to do so

We may contact you directly or through a third-party service provider regarding products or services you have signed up or purchased from us, in order to deliver transactional or service related communications. For example, we sometimes send emails to our users to inform them of important or significant product enhancements.

How we share Personal Data that we collect

Sharing your Personal Data with other Website users

When you use the Website, we share certain information about you with other Website users.

For collaboration: You can create content, which may contain Personal Data about you, and grant permission for others to view, share, edit, copy and/or download that content based upon settings that you or your administrator (if applicable) select. Some of the collaboration features of the Website display selected information from your profile to other Website users when you share or interact with specific content. For example, when you share an Outcome Chains to other users, your profile picture and name is displayed next to your shared content, so that other users with access to the information understand who shared the content.

OCI and its affiliates may disclose your Personal Data

We will share your Personal Data where there is a lawful ground to do so, such as:

To the extent required by law; if we have reason to believe that disclosure will assist in investigations relating to the security and protection of our systems; or in response to search warrants, subpoenas, other judicial or administrative process, national security letters, or other demands that compel the release of Personal Data under applicable law
In connection with a sale, merger, reorganization, or other transfer of OCI’s business (including under bankruptcy proceedings)
To meet our contractual obligations where a vendor or third party is processing Personal Data on our behalf.
To meet your sponsoring organization’s requirements

Data processors and disclosure of your Personal Data

OCI may use the services of third parties. Those services include but are not limited to:

Website hosting
Software as a Service (SaaS) applications for customer relationship management and data analytics
Processing payments
Marketing automation tools
Various other SaaS applications for which OCI controls data input

We only share your Personal Data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions, and are prohibited from utilizing, sharing or retaining your Personal Data for any purpose other than as they have been specifically contracted for (or with your prior consent).

How we store, secure and retain Personal Data

OCI uses data hosting service providers in the United States. We utilize industry-standard administrative, physical, and technical safeguards to protect Personal Data received from our users and website visitors. OCI will protect Personal Data by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Safeguards for OCI’s internal systems and infrastructure include transport layer security or secure sockets layer protocols to protect and encrypt Personal Data in transit, and data encryption at rest. These methodologies, unfortunately, cannot 100% guarantee that Internet transmissions will be protected, secured, or not otherwise intercepted.

We retain personal data only for as long as necessary for lawful basis of processing a service that you have requested, and thereafter for legitimate legal or business purposes. These might include retention periods mandated by law, contract or similar obligations applicable to our business operations; for preserving, resolving, defending or enforcing our legal/contractual rights; or as needed to maintain adequate and accurate business and financial records.

How we transfer Personal Data that we collect internationally

If you utilize our Website from a country other than the United States, your communications with us may result in transferring your personal information across international borders. In this case, your personal information is handled according the statements outlined in this Privacy Policy.

How you can access and control your information

Access and rectification of your Personal Data

You can access the Personal Data about you that OCI possesses for instance, to make changes or updates to it. Most changes to your Personal Data can be made from your account profile pages on our product website. For any information that you cannot change, please contact OCI for assistance at privacy@outcomechains.com.

Requests to stop processing your Personal Data

In some cases, you may ask us to stop processing your Personal Data except where processing is required by applicable law, or, where OCI has a lawful basis to continue doing so as required by law or permitted by applicable laws and regulations. Most communications to our users provide within them a mechanism to ‘opt out’ of data processing activities. If you are unable to locate within a communication to you the ability to opt out, please contact OCI for assistance at privacy@outcomechains.com. Administrative and contractual emails about your account and services may still be sent.

Providing consent or withdrawing consent

OCI may rely on your consent to collect certain Personal Data or to use it as described in this Privacy Policy. Where we rely on your consent however, you have the right not to consent. If you have provided consent, you have the right to withdraw your consent provided that the withdrawal of your consent does not affect OCI’s legal grounds for processing of your Personal Data before you withdrew consent. Moreover, OCI may have other lawful grounds, permitted or required by law, to preserve or to continue using your Personal Data. In OCI product website (e.g. app.outcomechains.com), you can find withdraw your consent information in Profile page. You can also contact OCI at privacy@outcomechains.com to withdraw your consent.

Deleting your Personal Data

Our product website gives you the ability to delete certain information about you from within the Website. For example, you can remove content that contains information about you using our delete feature in our product site, and you can remove certain profile information within your profile settings. You can also request your OCI account administrators to remove your information. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations. For any information that you cannot delete, please contact OCI at privacy@outcomechains.com for assistance.

Restricting the processing of Personal Data

You may ask that we restrict your personal data (i.e., keep but not use) where:

The accuracy of the personal data is contested
The processing is unlawful, but you do not want it erased
We no longer need the personal data, but you require it for the establishment, exercise or defense of legal claims
You have objected to the processing and verification as to our overriding legitimate grounds is pending

We can continue to use your personal data:

Where we have your consent to do so
For the establishment, exercise or defense of legal claims
To protect the rights of another
For reasons of important public interest

For restricting the process of Personal Data, please contact OCI with you request at privacy@outcomechains.com.

Data portability

You may request a copy of your Personal Data in an electronic format that you can take to other service providers. Depending on the context, this applies to some of your information, but not to all your information. Should you request it, we will provide you with an electronic file of your basic account information within 30 days by providing a link to a location where the data can be downloaded. To make data portability request, please contact OCI with you request at privacy@outcomechains.com.

Cookies and Other Technologies

We may use (or we may contract with service providers to use) various technologies to collect information about your activities while using our Website.

We may deploy on your computer or device with one or more “cookies” in order for our Website to perform optimally, facilitate your access to our Website, and to personalize your user experience, A cookie is a small data file that our Website saves on your computer or mobile device when you visit our Website. It enables our Website to remember your actions, browsing activities, favorite content, and preferences (such as clicking “Remember me” during login). Whenever you sign into our Website, we will record your user ID in a cookie file on your computer or mobile device.

Information collected by cookies may include:

Your browser or operating system
Your manner of connecting to the Internet (including the type of device you are using) and the name of your Internet service provider or wireless carrier
Your Internet protocol (IP) address
Data relating to malfunctions or problems occurring when you use OCI Website
App usage for statistical and research purposes

We use a combination of Google Analytics, marketing automation, and cookies on our Website that identify your computer to help us analyze traffic patterns on our Website as well as to provide you with a better experience by showing you content that matches your interests, improving content, and making the Website easier to use.

Through the use of a cookie, OCI may also automatically collect information about your online activity on our Website, such as the web pages you visit, the links you click, and the searches you conduct.

Google Analytics uses cookies to help OCI analyze how visitors use its Website. The information generated by the cookies about your use of OCI Website includes your IP address, and will be transmitted to and stored by Google on its servers.

Google will use this information for the purpose of evaluating your use of our Website, creating reports on website activity, and providing other services relating to Internet usage. Google may also pass this information onto third parties when required to do so by judicial or administrative process or otherwise to the extent required by law, or when such third parties process the information on Google’s behalf.

By using one of our Website, you consent to the processing of data about your visit by Google in the manner and for the purposes set out above.

OCI’s use of cookies conforms to industry standards. Should you wish to not have cookies enabled when using our Website, you can adjust your browsers settings accordingly. However, this may cause issues in accessing information where authorization is required.

Other Technologies

OCI may use standard Internet technology, such as web beacons (also called “clear GIFs” or “pixel tags”), locally stored objects (often referred to as “flash cookies”), and other similar technologies, to deliver or communicate with cookies and track your use of our Website and content presented via the Website. OCI may also include web beacons in email messages to determine whether messages have been opened and acted upon. The information OCI obtains in this manner enables customization of the programs and Website that OCI offers and measures the overall effectiveness of OCI’s online content.

‘Do Not Track’ notifications.

Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.

Children’s/Minor’s Privacy

OCI does not allow minors, meaning individuals under the age of 18, to utilize any of its Website. Our Website are not targeted to nor intended to be consumed by or designed to entice the use by individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal data, please contact us at privacy@outcomechains.com.

Privacy Shield

OCI complies with the EU-U.S. Privacy Shield Framework and 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. OCI 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/

OCI has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.

EU Persons may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website. To learn more about the Privacy Shield Framework at https://www.privacyshield.gov.

OCI is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.

In compliance with the Privacy Shield Principles, Outcome Chains commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Outcome Chains at: privacy@outcomechains.com

Outcome Chains has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.

ONWARD TRANSFERS OF PERSONAL DATA

We will not transfer Personal Information originating in the EU to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to your Personal Information as required by the Principles of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We will only transfer Personal Information to cloud service providers who need the information in order to provide services to or perform activities on our behalf. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, OCI, is potentially liable.

Amendments to this Policy

OCI reserves the right to amend this Privacy Policy at any time at our sole discretion. If we make any changes, we will post those changes here and update the “Last revised” date at the top of this Privacy Policy. Where you have previously consented to our use of your personal data, your continued use of the website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page.

How to contact us

If you have any requests, questions, concerns or complaints about our Privacy Policy, our practices or our Website, you may contact us by email at privacy@outcomechains.com. Alternatively, you may also contact us by either of the following means:

By Mail:

Attn: Privacy

Outcome Chains, Inc.

17065 Camino San Bernardo, Suite 100

San Diego, CA 92127

By Phone: 844.624.2666

We will respond to all requests, inquiries or concerns within thirty (30) days.

Last updated: October 16, 2019