Privacy Policy
Last Updated: May 1, 2024
1. About this Policy
Thank you for using EASL TECH, INC. and visiting our website. Your privacy is important to us, and we have adopted this Privacy Policy to memorialize the data collection and disclosure practices of our corporate website at www.easltech.com, including any mobile applications we provide, our online platform software, and any web pages we control on any third party websites (collectively, the “Service”). The Service is owned and operated by EASL TECH, INC., a Delaware corporation (together with our affiliates, “EASL,” “we,” “us” or “our”). This Privacy Policy applies to anyone using or browsing our Service, and to information provided to us or to our affiliates, customers, or users of the Service (“users,” “you” or “your”). We encourage you to read this Privacy Policy carefully before using the Service or transacting business with us. By using the Service, you are accepting the practices described in this Privacy Policy, and the collection, use, and transfer of your information as described herein. If you have questions about any of our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.
2. Consent
EASL takes privacy seriously. As a leading provider of software and services for supply chain processes, we are committed to establishing and maintaining policies and procedures which protect the privacy of personal information gathered from our customers, prospects, and other users of our Service. By using or registering with any part of our Service, you consent to this Privacy Policy. If you do not agree with any provisions of this Privacy Policy, you may not use our website, platform software, or any other part of the Service. Please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our Service, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy, and you specifically consent to the transfer of your information to the United States.
3. Collection of Information
We collect Personal Information in connection with our Service, but we do not collect any more information than reasonably needed to offer the Service. When we use the term “Personal Information” we mean information that can be used to identify an individual or is combined with individually identifiable information and may include your first and last name, by itself or combined with your email address, postal address, unique device identifiers, and other unique identifiers (such as login information), telephone number. On occasion, we may also collect Personal Information about third parties who may not be direct users of the Service, including Personal Information about your clients (“Clients”), but only if our users choose to provide it to us through the Service. Any time you share a third party’s Personal Information with us, you agree that you will have obtained all legally required consent from the third party to do so and for us to store such information through the Service on your behalf as described in this Privacy Policy. “Personal Information” also includes any credit card or debit card or other financial account information you may provide to us or to our third-party payment provider for billing purposes. We may send billing and payment information, including any credit card, debit card, or bank account information, through third-party billing systems so that we do not store all such information on our servers. EASL also collects “Non-Personal Information” about you. “Non-Personal Information” means information that is not Personal Information, including, without limitation, aggregated and anonymized information derived from your Personal Information. This may include de-identified search results and information collected by cookies and similar technologies as described below.
4. Use of Personal Information
EASL uses Personal Information about our users to assist us in setting up accounts; processing transactions you initiate (for example, any credit, debit or other billing account information collected from you by us or on our behalf by a third party payment gateway are generally only used to process purchase transactions authorized by you); providing customer service; providing newsletters and/or other communications or services which you have signed up for or otherwise agreed to receive; sending account- or transaction-related communications such as welcome letters and transaction confirmations; sending you emails or contacting you by telephone concerning new products and services and upcoming events; performing research and analysis aimed at improving our products, service and technologies; and managing our systems (for example, users’ names and email addresses are collected and used in the Service for purposes of managing the login authentication process, and to allow the application to send notifications to end users, such as email notice informing the user that a scheduled task has been completed). We may also use this information for internal purposes to help us diagnose problems, monitor traffic patterns, and otherwise continually improve our Service. Subject to our obtaining from you any consent (or providing you any ability to refuse consent) as required by applicable laws and directives relating to privacy and electronic marketing, we may call you, including the use of automatic dialer systems to your landline or mobile telephones, send SMS or MMS messages to you, or contact you by any means described above. You may opt out of these types of communications at any time by following the unsubscribe link located at the bottom of any e-mail, SMS, and MMS messages or by emailing us at unsubscribe@ealtech.com. Please note, however, that even if you opt out, we may still need to contact you to send you notices about your account or transactions with us where permitted by applicable law and privacy directives. EASL will not use Personal Information relating to third parties which are submitted by our users through the Service and stored on their behalf (such as information about our users) except to provide the Service to our users or to respond to a request by any such third party (such as a request to access, modify or delete their Personal Information). EASL also uses Non-Personal Information collected through cookies and other automatic information-gathering technologies as described below in this Privacy Policy.
5. Disclosure of Personal Information
EASL will not disclose your information except as specifically described in this section. Subject to our obtaining from you any consent (or providing you any ability to refuse consent) as required by applicable laws and directives relating to online privacy and electronic marketing, we may disclose Personal Information and Non-Personal Information about you to agents, contractors, and service providers or others engaged to perform functions on our behalf, such as providing data storage, hosting our website, conducting audits and performing web analytics; or to market EASL products and services to you (for example, to send you messages concerning new EASL features, products or special offers). Any third-party service providers with whom we share Personal Information are required to keep such Personal Information confidential and to use it only in a manner consistent with this Privacy Policy and not for their own marketing purposes. With your consent and at your request, we may also disclose Personal Information about you to other persons, such as your Clients or other persons with whom you wish to share information via the EASL Service. We license media broadcast and viewership data that does not contain Personal Information to our partners (e.g. advertisers, marketers, ad tech companies, and other partners) so they may combine it with their own data in order to conduct various activities for their own marketing and commercial purposes. While EASL does not share consumers’ Personal Information with our partners for their marketing or commercial purposes, we recognize that some of our partners may obtain Personal Information from other sources and combine it with their own data. We may also disclose Personal Information to third parties if we have a good-faith belief that such disclosure is reasonably necessary (a) to enforce or apply the terms and conditions of the Service, including investigations of potential violations thereof, (b) to comply with legal or regulatory requirements or a governmental request, (c) to protect the rights, property or safety of EASL, other users or other third parties, (d) to any law enforcement authority, such as a police department or regulatory authority in connection with an investigation, or (e) to detect, prevent or otherwise address fraud, security or technical problems that may arise. We may disclose Non-Personal Information to any third party for any reason in our sole discretion. EASL may also transfer any information in its possession (including your Personal Information and Non-Personal Information) to a third party in the event of a reorganization, spin-out, sale, merger, or transfer of some or all of the assets of EASL, or in the unlikely event of a bankruptcy, liquidation or receivership of our business. If we are involved in a merger, acquisition, or asset sale, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business, we will provide affected users notice through the EASL website at least thirty (30) days before your information becomes subject to a different Privacy Policy. Where our users submit the Personal Information of third parties through our Service and we store this information on their behalf, we will not disclose this information to third parties to use in marketing or to send promotional messages.
6. Accessing and Updating Personal Information
Generally, our platform software is configured to enable you to give you or your Clients the means to access their own personal information for the purposes of deleting it and/or correcting it. In the alternative, you have a right to contact us to access certain personal records we hold about you. This is called a “subject access request”, which you can make by writing to EASL TECH, INC., 142 East Road, Building 2, Doylestown, PA 18901. A fee may be payable by you if you make any requests that would require a disproportionate effort on our part, but we will not charge you until we have told you how much the fee is and what it is for, and you have told us you still want to proceed. We ask individuals contacting us about their Personal Information to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, unless responding to your request would require a disproportionate effort. Please e-mail us at privacy@easltech.com or contact us at the address stated below with any questions if you need assistance accessing or changing your Personal Information or if you would like to have your Personal Information deleted from our servers. Please be aware that if you delete your Personal Information, you may not be able to continue to use our Service. Generally, we will retain your information for as long as your account is active or as needed to provide you with services. We may also retain and use your information as reasonably necessary to comply with our legal and audit obligations, resolve reported and potential disputes, and enforce our agreements. Please note that if you ask us to delete your Personal Information, we may in our good-faith discretion, and to the extent permitted by applicable law and privacy directives, retain certain information for purposes of these requirements.
7. Cookies and Automatic Information Gathering Technologies
Non-Personal Information (including aggregate, technical, or demographic information) can also be collected through the standard operation of our internet servers and logs as well as other automatic data collection tools such as “cookies” and other similar technologies. By using our website or the Service, you consent to the placement and use of cookies and similar technologies on your hard drive or computing device. A “cookie” is a small text file that is recorded either temporarily or persistently on your hard drive and that a website can use in order to recognize visitors who revisit a website so as to facilitate their ongoing access to and use of the website. Information we may collect through cookies and other similar technologies includes your IP address, browser type, language preference, operating system, the name and type of device, the operating system of your device, the date and time of each user visit or request, and the EASL service endpoints that you accessed or visited during your use of the Service. These technologies do not collect and are not associated with Personal Information. We reserve the right to use aggregated and de-identified Non-Personal Information collected from our users through such automatic information gathering technologies for any reason in our sole discretion, including but not limited to performing statistical analysis of the aggregated information, including analysis about the behavior of visitors to our website on an aggregated, anonymous basis, or to share such information with third parties. We do not use cookies or other information-gathering technologies to gather information from third parties whose information you submit to us through the Service unless they actually use our website or the Service themselves. You may prevent our use of cookies to collect information about you by adjusting the option that is available in most web browsers to deny or accept cookies. Recognize, however, that cookies may be necessary in order to provide certain features such as the customized delivery of certain information. For example, EASL requires the use of cookie technology so that we can guarantee we’ll present the correct information to users as they move from screen to screen. These cookies are “session-specific” and are not used to record personal information. They are used to the that only authenticated users can navigate the application. EASL users who disable their Web browser’s ability to accept cookies will be able to use some parts of the Service but not others; e.g., they may browse our website, but they will not be able to successfully use our online platform software. We also support non-session cookies for allowing the user to automatically remember their login credentials to gain access to the Service. Finally, EASL may use web beacons or other unique identifiers to allow it to determine which messages or elements of a media campaign generate responses. This allows EASL software to gauge the effectiveness of certain communications.
8. Children
We do not knowingly collect Personal Information from children less than 13 years of age. Nor do we authorize children less than 13 years of age to use the Service. If we learn that we have inadvertently collected Personal Information from a child under the age of 13, upon receipt of notice from the child or the child’s parent or legal guardian, we will use reasonable efforts to delete that child’s Personal Information from our systems.
9. Data Hosting and Information Security
EASL takes reasonable precautions to protect Personal Information in its possession from loss, misuse, unauthorized access, disclosure, alteration, and destruction. EASL limits access to personal information and data to those persons in EASL’s organization, or agents of EASL, that have a specific business purpose for maintaining and processing such information and data. Individuals who have been granted access to Personal Information are made aware of their responsibilities to protect the security, confidentiality, and integrity of that information. In addition, we only host your Personal Information on servers that EASL owns or leases and manages. Unfortunately, however, no data transmission over the Internet and no method of data storage can be guaranteed to be secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we do not guarantee its security.
10. Your California Privacy Rights
You may have heard of the California Privacy Protection Act which provides certain rights to California (CCPA) residents in connection with their Personal Information. Our Services are not currently subject to the CCPA. However, we do provide notice and transparency about our collection and use of Personal Information as described in the Privacy Policy.
11. Third Party Websites; Message Boards, Social Media, and Other Online Forums
Please note that we are not responsible for the privacy policies, practices, or the content of websites owned by others that you may link to or that may be linked from the Service. Accordingly, we encourage you to review the privacy policies and terms of service of any such websites so that you understand how those websites collect, use, and share any Personal Information they may collect about you. When you choose to post comments, messages, and/or profile content on our Service, some of the content is viewable by other users and third parties and, in the case of public online forums, is publicly viewable. Accordingly, you should exercise discretion with regard to what Personal Information you post on our Service and on third-party websites, and you should not publicly post highly confidential, sensitive, or embarrassing information. EASL is not responsible for how third parties who view your Personal Information and other information that you post or make available publicly through the Service may use your information (such as to send you unsolicited messages).
12. Changes to this Policy
From time to time, we may desire to use customer information for new, unanticipated uses not previously disclosed in our Privacy Policy. EASL may modify or update this Privacy Policy from time to time with any such policy changes or any other changes deemed necessary or desirable in EASL’s sole discretion, by posting an updated Privacy Policy on the Service. If we make any material changes, we will notify our users by email (sent to the e-mail address specified in your account) or by means of a notice on the Service, prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. You can always check the “last updated” date at the top of this document to see when the Privacy Policy was last changed. Your continued use of our website and/or Service following the effective date of an updated Privacy Policy constitutes your consent to the contents of such policy. However, we will not apply any material changes retroactively to any information we collected from you before such changes took effect, without your affirmative consent to do so. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE SERVICE AFTER THE EFFECTIVE DATE OF SUCH CHANGES. Please note that upon leaving the Service, any Privacy Policy in effect immediately prior to your departure shall continue to be binding on you and applicable to the data collected from you prior to such departure.
13. Privacy Shield
We comply with the Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom, or Switzerland. We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement, and Liability. If there is any conflict between this Privacy Policy and these Privacy Shield Principles, the Privacy Shield Principles shall govern. The types of data we are collecting under the Privacy Shield, the purposes for which each such type of data is being collected and used, and the types of third parties to which we may disclose such information (and the purposes of such disclosure) are set forth above in this Privacy Policy. You have rights, as set forth above in this Privacy Policy, to access, edit, and have deleted your Personal Information. The choices and means offered to you for limiting the use and disclosure of your Personal Information are set forth above in this Privacy Policy. Notwithstanding any language to the contrary in this Privacy Policy, in cases of onward transfer to third parties of Personal Information of EU, UK, or Swiss individuals received pursuant to the Privacy Shield, we are potentially liable. In compliance with the Privacy Shield Principles, we commit to work to resolve complaints about your privacy and our collection or use of your Personal Information. EU, UK, or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact us at EASL, Inc. Attention: Privacy Complaints 142 East Road, Building 2, Doylestown, PA 18901 USA Email: privacy@easltech.com. We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to the American Arbitration Association, a non-profit alternative dispute resolution provider located in the United States. If you do not receive a response to your complaint from us within forty-five (45) days, or if your complaint is not satisfactorily addressed, please visit http://go.adr.org/privacyshield.html for more information and to file a complaint. Please note that if your complaint is not resolved through the above channels, you may have the right, under certain limited conditions, to invoke binding arbitration before the Privacy Shield Panel to be created by the US Department of Commerce and the European Commission or the applicable UK or Swiss authorities. We are subject to the investigatory and enforcement powers of the United States Federal Trade Commission (“FTC”) with respect to its compliance with the Privacy Shield.
14. Contact Us
To ask questions about our Privacy Policy, obtain more information, or lodge a complaint, please contact us using one of the following methods: By Mail: 142 East Road, Building 2, Doylestown, PA 18901 By Telephone: (267) 218-3311 By E-Mail: privacy@easltech.com.