Please click on a topic below to learn more:
- “Content” vs. Other Information
- Other Information We Collect
- Access to Content
- Purposes for Which We Use Personal Data
- How We Share Information
- Your Choices and Rights
- Data Retention
- How We Protect Your Information
- Blogs; Forums
- Linked Sites; Third Party Widgets
- International Transfers and Privacy Shield Notice
- Changes to this Policy
- How to Contact Us/Dispute Resolution
- English Version Controls
Who are “we”?:This Policy sets out how Appropos, LLC, a Michigan limited liability company, d/b/a Envoy and our affiliated companies (together, “Envoy” (or “we”) handles your personal data. Envoy is the data controller for your personal data. Where processing of personal data is undertaken by our affiliated companies, they are joint controllers with Envoy for your personal data. Correspondence can be directed to the Envoy Legal Department (email@example.com).
Who are “you”?:This Policy applies to any visitor to our Sites; users of the Services; individuals who contact us or with whom we communicated via phone, email, or otherwise; and Customers, including both free trial and paid account holders.
To EU Residents:Envoy processes your personal data in accordance with the EU data protection legislation, including national or international legislation implementing the EU Data Protection Directive (until superseded), the Privacy in Electronic Communications (“ePrivacy”) Directive (EU), and the General Data Protection Regulation (EU) 2016/679 (“GDPR”), as amended or superseded.
1. “Content” vs. Other Information.
Our Services permit Customers to share and manage information by creating, uploading, and attaching “Content” that can be shared, stored, and accessed through the Site. In this Policy, we distinguish between Content and all other information about you. We have no control over the information contained within Content, including any personal data. Content does not include usage information we collect about how users access, create, share, and manage Content (e.g., file sizes or access logs). Envoy is a data processor of the Content, and will only process personal data from the Content on behalf, and under the instructions, of our Customers (the data controllers) or where otherwise required by applicable laws. For more information about Content, please refer to the agreement that governs your use of the Services.
Sensitive Data. We have no control over whether Sensitive Data is contained in Content. However, we do not intentionally collect - and will not request - Sensitive Data. If an Envoy employee discovers that we have received Sensitive Data, the employee will inform a designated contact within our company who will assess the processing of such data. “Sensitive Data” means personal data that discloses an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or criminal proceedings, and also includes data concerning health, genetic data, biometric data, and data concerning a person’s sex life or sexual orientation.
2. Other Information We Collect About You.
This section describes information that is not Content.
We collect personal data about you directly from you, from others (e.g., your employer if you use an enterprise account), and automatically when you use the Services. If the personal data we process is needed to comply with law, or to enter into or perform an agreement with you, we will inform you accordingly at the time of such data collection. If we cannot collect this data, we may be unable to on-board you as a customer or provide products or services to you.
Information We May Collect Directly from You.
At Account Creation.An email address is required to provide a new Envoy account (paid or trial). Without this, we are unable to create your account. You may choose to provide other information at account creation, including contact information (full name, phone number, etc.), employment details (company name/size, your job title, etc.), and a system administrator’s email (if not you).
When Purchasing Services. If you purchase a paid subscription, you may need to provide us billing and payment information, including full name, company name, billing/shipping address, and credit card number. If you do not provide us this information, you may be unable to subscribe and your access to our Services may be limited.
In Online Submissions. We collect information through interactive features of our Sites - e.g., when you submit online forms; request customer support; or respond to “Contact Us” invitations. Personal data gathered may include contact information (full name, phone number, email, etc.), employment details (company name/size, job title, etc.), information about your use of Envoy, and any other information you choose to share.
In Other Communications. You may share information in communications with us relating to the Services, including during phone calls (and call recordings), chats, or over email. Personal data gathered may include contact information, employment details, user preferences, and any other information you choose to share. Please only provide us personal data that we need in order to respond to your request.
Information We Collect From Your Employer. If you use the Services through an enterprise account, your employer will provide Envoy your email address in order to provision your account. Your employer may choose to share additional information about you including your contact information (e.g., full name, phone number, etc.), and employment details (e.g., job title).
Information We Collect From Third Parties.
When Purchasing Services.A third-party intermediary is used to manage credit card processing. It is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.
Third Party Sources.Subject to applicable laws, we may gather information about you from lead-sharing tools including LinkedIn Lead Generation, or as leads from Envoy’s global resale partners, as well as public information - including internet searches relating to you or your company - in order to better service your account and to provide more relevant assistance and marketing.
Our Customers are responsible for ensuring that Content is collected and handled (including any personal data therein) in compliance with applicable laws. As a processor, we handle Content as directed by our Customers (the controllers), pursuant to our relevant customer agreements. We only access Content as necessary to:
- Respond to customer support requests (including, with respect to enterprise users, company administrator requests).
- Comply with the law or legal proceedings; for example, we may disclose Content in response to lawful requests by public authorities, including responding to national security or law enforcement disclosure requirements.
- Investigate, prevent, or take action against suspected abuse, fraud, or violation of our policies and terms.
4. Purposes for which We Use Personal Data
We use the personal data we collect under this Policy in furtherance of our legitimate business interests, which include:
- Provision of Services:To provide and operate our Services, fulfill your orders and requests, process your payments, for bug and error reporting and resolution, to perform upgrades and maintenance, and for similar purposes.
- Customer Support:To communicate with you about your use of the Services; respond to your communications, complaints and inquiries; provide technical support; and for other customer service and support purposes.
- Personalization: To tailor content we send or display to you in order to offer location customization and personalized help and instructions, and to otherwise personalize your experience using the Services.
- Marketing and Promotions:For direct marketing and promotional purposes. For example, we may use contact information such as your email address to send you newsletters, special offers or promotions, or to otherwise contact you about Envoy products or information we think may interest you. As explained above, we do not use Content for direct marketing purposes. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them. You may opt out of receiving marketing emails by following the opt-out instructions in the email or emailing firstname.lastname@example.org. We may still email customer service and transaction-related communications, even if you have opted out of receiving marketing communications.
- Advertising: To assist in advertising the Services on third party websites.
- Analytics and Improvement:To better understand how users access and use the Services, and for other research and analytical purposes, such as to evaluate and improve the Services and to develop additional products, services, and features. While we may collect and analyze usage details (e.g., storage size used, access logs, etc.) related to Content, we do not actually access Content for these purposes.
- Comply with Legal Obligations: To comply with the law or legal proceedings; for example, we may disclose information in response to lawful requests by public authorities, including responding to national security or law enforcement disclosure requirements.
- General Business Operations:Where necessary to the administration of our general business, accounting, recordkeeping, and legal functions.
Purpose of Processing /Legitimate Business Interests (see above)
Legal Bases of Processing (EU Users)*
Provision of Services
Marketing and Promotions
Analytics and Improvement
Protect Rights and Prevent Misuse
Comply with Legal Obligation
General Business Operations
*For the personal data from the EU that we process, this column describes the relevant legal bases for such processing under GDPR (and local implementing laws of EU member states); this does not limit or modify the obligations, rights, and requirements under the privacy laws of non-EU jurisdictions.
** For the personal data from the EU, the processing is in our legitimate interests, which are not overridden by your interests and fundamental rights. Marketing to EU data subjects is done only with opt-in consent.
5. How We Share Information
We will not sell information about you to a third party or allow a third party to use information we provide for its own marketing purposes. We may share information about you with your consent, at your request, or as follows:
Content and Usage.Envoy is a data processor with respect to Content and certain other user information we collect in providing the Services to our customers. This means: (a) the Customer controls the information and determines how it may be used, and (b) we will process this information only under the written instructions of our Customer or where otherwise required by applicable laws. So, if you use the Services, Content and other information associated with your account (e.g., who has accessed, shared, amended, created, edited, or deleted Content) may be disclosed to the Customer or an administrator for the Customer account. Content that customers choose to share with, or make available to, other users is shared as designated by you, and you should consider that it may be further shared by your collaborators; we are not responsible for, nor does this Policy apply to, the collection, use, processing, or sharing of Content by other users in this manner.
Other Information.Some of the features and functionality of the Services involve disclosure of your personal data to other users of the Services; for example, your name, and email address may be displayed when sharing content.
Payment Processors. If you use a third party to facilitate your payment obligations, we will share certain account-usage and billing-related information about your account with such third party for billing and business administration purposes. Resellers and payment processors are independent data controllers of your personal data.
In Testimonials.With your consent, we may publish Customer testimonials you share with us, which could contain personal data such as your full name and other information you choose to share. If you wish to update or remove your testimonial, please notify us at email@example.com.
To Our Service Providers.We may share information about you with third party vendors, consultants and other service providers (data processors) who are working on our behalf or providing services to us. We obtain appropriate contractual protections to limit these service providers’ use and disclosure of any information about you that we share with them.
Infrastructure Processors.We use certain third parties for some of the infrastructure used to host data that is submitted to the Envoy platform, including cloud providers.
Service Processors.We use third party service providers to process your personal data to assist us in business and technical operations. Envoy has data processing agreements with such service providers, and their use of and access to personal data is limited to specific purposes. They provide services relating to: billing, customer support, internet and connectivity, marketing (direct mail, email, lead generation), security, user experience.
Subcontractors: Independent Contractors. We may employ the assistance of independent contractors to work on specific projects. We train these independent contractors on applicable Envoy policies and they are required to adhere to substantially the same data security practices as are Envoy employees.
As Required by Law. We release information about you if we believe we must do so to comply with the law or a subpoena, bankruptcy proceeding, or similar legal process.
To Protect Rights. We may disclose information about you, such as your name, contact information, and billing information, to enforce our agreements with you or to protect the rights and safety of Envoy, our customers, our users, and the general public, or as evidence in litigation in which we are involved.
In a Business Transaction.If Envoy is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred to the acquiring entity as part of the transaction, and may also be reviewed as part of the due diligence review for the transaction. For example, we may need to provide a list of all customer accounts and payment histories.
Aggregate and Anonymized Information. We may share aggregate or anonymized information about users with third parties for marketing, advertising, research, or similar purposes. For example, if we display advertisements on behalf of a third party, we may share aggregate demographic information with that third party about the users to whom we displayed the advertisements.
In order to make our platform as user-friendly as possible, we – like many other companies – use “cookies”.
Cookies. A cookie is a small text file that is stored in your web browser that allows Envoy or a third party to recognize you. Cookies can either be session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years. Cookies placed by the website you’re visiting are sometimes called “first party cookies,” while cookies placed by other companies are sometimes called “third party cookies.”
Types of Cookies.
Essential Cookies.These are first party cookies that are sometimes called “strictly necessary” as without them we cannot provide much of the functionality that you need on the Services.
Analytics Cookies.These cookies track information about how the Services are being used so that we can make improvements and report our performance. They collect information about how visitors use the Services, which site the user came from, the number of each user’s visits, and how long a user stays on the Services. We might also use analytics cookies to test new pages or features to see how users react to them. Analytics cookies may either be first party cookies or third party cookies.
Preference Cookies.These cookies are also sometimes called “functionality cookies.” During your visit to the Services, cookies are used to remember information you have entered or choices you make (such as your username, language, or region) on the Services. They also store your preferences when using the Services, for example, your preferred language. These preferences are remembered, through the use of persistent cookies, and the next time you visit the Services you will not have to set them again.
Targeting or Advertising Cookies.These third party cookies are placed by third party advertising platforms or networks in order to deliver ads, track ad performance, and enable advertising networks to deliver ads that may be relevant to you based upon your activities (this is sometimes called “behavioral” “tracking” or “targeted” advertising). More information about how cookies are used for advertising purposes is explained below in Behavioral Targeting and Remarketing.
Clear GIFs.Clear GIFs (a.k.a. web beacons or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, clear GIFs are embedded invisibly on web pages, and are not stored on your hard drive. We might use clear GIFs to track the activities of Site visitors and users of our Services, to help us manage content, and to compile statistics about usage. We and our third party service providers also might use clear GIFs in HTML e-mails to our customers to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
How to Disable Cookies.The “help” portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies, be aware that some features of our Services may not function.
To learn more about how to control cookie settings through your browser:
- Click here to learn more about the “Private Browsing” setting and managing cookie settings in Firefox.
- Click here to learn more about “Incognito” and managing cookie settings in Chrome.
- Click here to learn more about “InPrivate” and managing cookie settings in Internet Explorer.
Opting Out of Ad Networks. If you wish to not have this cross-site information used for the purpose of serving you targeted ads, you may opt-out of many ad networks by clicking here (or if located in the European Union, click here). You will continue to receive ads on the sites you visit, but the ad networks from which you have opted out will no longer target ads to you based upon your activities on other sites. Please note, however, that these opt-out mechanisms are cookie based; so, if you delete cookies, block cookies or use another device, your opt-out will no longer be effective. For more information, go to www.aboutads.info.
Do Not Track. Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. In the meantime, you can use the “help” portion of the toolbar on most browsers to learn how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies, be aware that some features of our Sites may not function.
7. Your Choices and Rights
Closing Your Account.If you wish to close your account, you may do so by logging in and using the Account Administration settings or by contacting us at firstname.lastname@example.org. If you shared any Content or information through our Services with other users, such Content or information will continue to be accessible to such users.
Content.Requests to access, delete, or modify Content will be directed to the Customer who owns the account. If you wish to request access to personal data contained in Content to delete, modify, or limit use, please provide us with the name of the Customer who submitted your information to our Services. We will refer your request to that Customer and will support them as needed.
Access and Correction. Contact us at email@example.com access or update account profile information. Envoy will support its customers as needed to update your account information.
Marketing Choices. Customers can always opt out of being contacted by us for marketing or promotional purposes by following the opt-out instructions located in the e-mails we send, by changing the account privacy settings, or by emailing us at firstname.lastname@example.org. Please note that if you opt out of marketing communications, Envoy will continue to send you transactional or service-related communications, such as service announcements and administrative messages. If you do not wish to receive these, you have the option to cancel your account by logging in and using the Account Administration settings or by emailing us at email@example.com.
Users in the European Economic Area.
Individuals in the EEA have the following rights with respect to their personal data:
- Access. You can ask us to confirm whether we are processing your personal data; give you a copy of that data; and provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any profiling, to the extent that such information has not already been provided to you in this Policy.
- Rectification. You can ask us to rectify inaccurate information. We may seek to verify the accuracy of the data before rectifying it.
- Erasure. You can ask us to erase your personal data, but only where it is no longer needed for the purposes for which it was collected; you have withdrawn your consent (where the data processing was based on consent and there is no overriding grounds for the processing); following a successful right to object (see 'Objection' below); it has been processed unlawfully; or to comply with a legal obligation to which we are subject. We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims. There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.
- Restriction.You can ask us to restrict (i.e., keep but not use) your personal data, but only where its accuracy is contested (see 'Rectification' above), to allow us to verify its accuracy; the processing is unlawful, but you do not want it erased; it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend legal claims; you have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your personal data following a request for restriction where we have your consent; to establish, exercise, or defend legal claims; or to protect the rights of another natural or legal person.
- Objection. You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. In addition, you can object to the processing of your personal data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing without providing any reason. We will then cease the processing of your personal data for direct marketing purposes.
- Opt Out.You can opt out of having your personal data disclosed by us to a third party if such third party is not acting as an agent to perform task(s) on behalf of and under the instruction of Envoy. You can also opt out of having your personal data used by us for a purpose materially different from the purpose(s) for which it was originally collected or for which you subsequently authorized us to use it. To do so, send an email message to the email address listed below under “How to Contact Us” stating one of the following: (1) “I would like to opt out of third-party disclosures”; (2) “I would like to opt out of having my personal data used for a materially different purpose”; or (3) “I would like to opt out of both third-party disclosures and having my personal data used for a materially different purpose.”
- Portability.You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another Data Controller, but only where our processing is based on your consent or on a contract and the processing is carried out by automated means.
- Withdrawal of Consent. You can withdraw your consent in respect of any processing of personal data which is based upon a consent which you have previously provided.
Please note that the rights contained above may not be applicable to information collected through Envoy’s use of session cookies (see Section 6), which is automatically deleted when your session is terminated or expires.
8. Data Retention
We keep your personal data for as long as reasonably necessary for the purposes set out in Section 4 above. Except as noted below, we will retain your account profile data as necessary for our legitimate business purposes or to comply with our legal obligations (such as record keeping, accounting, fraud prevention and other business administrative purposes); generally, where we no longer have a legitimate business purpose to retain it, we will anonymize or delete such personal data within 180 days after the closing of your account. However, we will maintain your personal information longer where required for tax or accounting purposes, to ensure we would be able to defend or raise a claim, or where we have a specific need to retain, though we will generally not keep personal data for longer than seven years following the last date of communication with you. Legitimate business purposes that we may rely on to keep your personal data when you are not a customer include direct marketing (where you have not opted-out) for up to two years, facilitating the restoration or establishment of a user account in the future, maintaining Envoy’s business intelligence systems for analytics and other internal purposes, etc. Where your information is no longer required, we will ensure it is disposed of in a secure manner.
9. How We Protect Your Information
We have implemented technical, physical, and administrative safeguards to protect your information. However, no company, including Envoy, can guarantee the absolute security of Internet communications. If you have any questions about how we secure your information please contact us at firstname.lastname@example.org.
10. Blogs, Forums
Our Sites may contain publicly accessible blogs and community forums (including the Community Features). Be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your information; if that happens, we will let you know why.
11. Linked Sites; Third Party Widgets
Links to Other Websites.Our Services include links to other websites with privacy practices that may differ from ours. Any information you submit to a website not belonging to Envoy is governed by that site’s privacy statements, not this one. We encourage you to carefully read the privacy statement of any website you visit.
12. Children’s Personal Data
The Services are not directed toward children and we do not encourage children to participate in providing us with any personally identifiable information. We do not knowingly collect any personal data from children under the age of 18. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal data through the Services. If you have reason to believe that a child under the age of 18, without a parent or guardian's consent has provided personal data to us through the Services, please contact us at firstname.lastname@example.org, and we will use commercially reasonable efforts to delete that information.
13. International Transfers and Envoy Privacy Shield Notice
International Transfer of Data. We are based in the United States and the information we collect is governed by U.S. law. The information we collect may be transferred to, used from, and stored in the United States or other jurisdictions in which Envoy, our affiliates, or service providers are located; these jurisdictions (including the United States) may not guarantee the same level of protection of personal data as the jurisdictions in which you reside. By using the Services, you acknowledge and agree to any such transfer of information outside of the jurisdiction in which you reside.
U.S.-EU Privacy Shield Certification.Envoy participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and Principles (collectively, the “Privacy Shield Principles”). Envoy will comply with the Privacy Shield Principles with respect to the personal data we receive in the United States from the European Economic Area. You can review the Privacy Shield Principles, learn more about Privacy Shield, and view our Privacy Shield certification at https://www.privacyshield.gov/. Envoy’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
Law Enforcement Requests.In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Onward Transfers. Third parties who process personal data on our behalf must agree to use such personal data only for the purpose for which it is provided by us and they must contractually agree to provide adequate protections for personal data. Envoy will continue to be liable for any onward transfers of personal data to such third parties. Where required by applicable data protection laws, we have ensured that such third parties sign standard contractual clauses as approved by the European Commission or other supervisory authority. You can obtain a copy of such safeguards by contacting us (see below).
Complaints or Questions About Our Privacy Shield Certifications. If you have any questions or complaints regarding our Privacy Shield Certification, you may contact us at email@example.com. We will promptly investigate and attempt to resolve any complaints, and will respond to your complaint within 45 days of receiving any such complaint. If you are a user located in the EEA whose complaint cannot be resolved through this process, we will participate in the dispute resolution process administered by JAMS. For information about how to initiate a Privacy Shield claim with JAMS, please contact JAMS at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim. Under certain conditions (which are described on the Privacy Shield website), you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
14. Changes to this Policy
We may update this Policy to reflect changes to our privacy practices. If you are an Envoy customer and we make any material changes that affect the way we treat information that we have previously collected from you, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice through the Services prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices.
15. How to Contact Us/Dispute Resolution
If you have any questions or concerns regarding the way in which your personal data is being processed or you want to exercise your rights above, please reach out to Envoy using the contact information below:
Envoy’s CFO, who serves as Company’s data protection contact, and can be contacted at firstname.lastname@example.org.
If you remain dissatisfied, you have the right to reach out directly to the Data Protection Authority in your jurisdiction. We do ask that you please attempt to resolve any issues with us first, although you have a right to contact the Data Protection Authority at any time.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.
16. English Version Controls
Non-English translations of this Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.