Privacy Policy



This Privacy Policy ("Policy") describes the manner in which Agoreo, LLC. ("Agoreo") handles personal information collected from individuals ("you" or "users") by AGOREO through AGOREO websites or in connection with AGOREO's delivery of services to its customers. In this Policy, the term "personal information" refers to information relating to an identified or identifiable natural person.

This Policy applies to all AGOREO websites that directly link to this Policy when you click "Privacy Policy" in the website footer. Please refer to the privacy policies of any linked third party website to learn how the operators of those websites collect and use information that is gathered through those websites.


INFORMATION CATEGORIES

AGOREO collects and uses personal information both on its own behalf and in connection with its delivery of services to its customers. This Policy is divided into separate sections to distinguish these different categories of information.



INFORMATION COLLECTED OR USED BY AGOREO ON ITS OWN BEHALF



NOTICE

AGOREO will notify you about the purposes for which it collects and uses information about you, how to contact AGOREO with inquiries or complaints, the types of third parties to whom it discloses personal information, and the choices and means the organization offers individuals for limiting its disclosure. This notice will be provided by this Policy, which is available from AGOREO's home page so that you may review it before you disclose personal information to AGOREO.


CHOICE

AGOREO will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For Sensitive Personal Information, AGOREO will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

AGOREO will provide individuals with reasonable mechanisms to exercise their choices.


PERSONAL INFORMATION GATHERED

The AGOREO website has and might implement various features which allow those interested in AGOREO and its services to obtain more information about AGOREO, such as by subscribing to an AGOREO Newsletter, viewing a webinar, obtaining a free trial of an AGOREO service, purchasing a subscription to an AGOREO service, participating in a promotional event, or requesting a white paper. AGOREO asks those requesting such information to provide AGOREO with certain personal contact information that AGOREO may use to follow up with those interested in its services. The information AGOREO may collect includes first and last name, company or organization, title or position within the company or organization, postal address, phone number, email address, and credit card information. AGOREO stores this information and uses this information internally to invoice and provide support to its customers and in addition for AGOREO's own marketing purposes.


TECHNICAL INFORMATION GATHERED ONLINE

AGOREO may employ web tracking technologies, such as log files and web beacons, in order to collect certain technical information about the operation of its websites and the behavior of visitors to the websites. The information collected may include: The URL of the site that you came from before visiting AGOREO's website; your computer's IP address; the browser you are using; the pages that you visit on the AGOREO website; search terms that were used to reach the AGOREO website. AGOREO websites also use cookies that track anonymous traffic data and to authenticate users and keep track of users' sessions. Some cookies are used to allow users to enter the portions of the AGOREO website reserved for registered AGOREO customers or to govern survey voting. AGOREO may use cookies and web tracking technologies to associate your online behavior with your personal information and use that information internally for AGOREO's marketing purposes.


ONWARD TRANSFER

AGOREO does not disclose personal information submitted to AGOREO to any third party, except as follows: • AGOREO reserves the right to disclose personal information if required by law enforcement authorities, subpoena or other court order, or other governmental authority, and (to the extent permitted by law) to the extent necessary to protect the legal rights and personal safety of AGOREO and its employees and agents.


SECURITY

AGOREO maintains reasonable precautions designed to ensure the security of personal information covered by this Policy, and to protect such personal information from loss, misuse or unauthorized access, alteration, destruction or disclosure. AGOREO has a written Information Security Policy and Data Protection Procedures by which data security is to be maintained. Although AGOREO makes every effort to ensure security of its customer information, no data transmission over the Internet can be guaranteed to be 100% secure.


DATA INTEGRITY

AGOREO takes reasonable steps to ensure that personal information it collects is reliable for its intended use, accurate, complete and current. AGOREO does not use personal information in ways that are incompatible with the purposes for which the information was disclosed.


USER ACCESS TO PERSONAL INFORMATION

Upon request, AGOREO will grant individuals reasonable access to Personal Information that it holds about them. In addition, AGOREO will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.



INFORMATION RECEIVED OR USED BY AGOREO ON BEHALF OF ITS CUSTOMERS


NOTICE OF INFORMATION RECEIVED AND STORED BY AGOREO ON BEHALF OF AGOREO'S CUSTOMERS

AGOREO's services allow AGOREO's customers to send email communications to their customers ("end-customers"). In order for these services to be delivered, AGOREO's customers upload certain personal information about their end-customers to AGOREO's servers. Such information includes email addresses, and may also include other information such as names and addresses of the end-customers to whom the email communications will be sent. AGOREO does not control the categories of information that an AGOREO customer may choose to upload to AGOREO's servers. AGOREO stores this information on its servers on behalf of its customers, and acts merely as a data processor with respect to this data. This information is controlled by the AGOREO customer on whose behalf the information is stored.

AGOREO uses personal information about end-customers stored by AGOREO customers solely for the purposes of delivering services to AGOREO customers. This includes sending email communications to the end-customers and providing analytical reports to AGOREO customers relating to AGOREO services. AGOREO uses web tracking technologies to track the online behavior of end-customers as they interact with the electronic marketing materials sent on AGOREO customers' behalf. AGOREO associates such online behavior with personal information and provides this data to the applicable AGOREO customer; for example, if an end-customer clicks on a particular product featured in an email communication sent by AGOREO, the AGOREO customer may receive a report from AGOREO identifying the product interest of its end-customer.


CHOICE

Because information held on behalf of AGOREO customers is controlled by AGOREO customers, AGOREO cannot delete or modify that information. If you wish to opt-out with respect to information stored or used by AGOREO customers, you should contact the applicable AGOREO customer directly. Or use the customer specific opt out link provided by customer within the electronic marketing material.


DISCLOSURE OF INFORMATION STORED BY AGOREO ON BEHALF OF AGOREO'S CUSTOMERS

AGOREO does not disclose any end-customer personal information stored on behalf of its customers to any third party except to a) the AGOREO customer on whose behalf the information is stored, and b) to third parties that the AGOREO customer has requested, in writing, may receive such information.


SECURITY

AGOREO maintains reasonable precautions designed to ensure the security of end-customer personal information covered by this Policy, and to protect such personal information from loss, misuse or unauthorized access, alteration, destruction or disclosure. AGOREO has a written Information Security Policy and Data Protection Procedures by which data security is to be maintained. Although we make every effort to ensure security of end-customer information, no data transmission over the Internet can be guaranteed to be 100% secure. AGOREO Customer accounts are password-protected so that only AGOREO or the applicable AGOREO customer has access to personal information of end-customers. It is incumbent on the AGOREO customer not to divulge their password to anyone.


DATA INTEGRATED

AGOREO is not responsible for the data integrity of data held by AGOREO on behalf of AGOREO customers, because AGOREO acts solely as a data processor for such customers.


ACCESS

AGOREO cannot offer end-customers access to information stored by AGOREO on behalf of its customers. Such information is under the control of the relevant AGOREO customer, and you should contact that AGOREO customer if you wish to obtain access to any personal information about you which is held by them.



SOCIAL MEDIA SERVICES

In order to utilize certain AGOREO services, you will need to permit AGOREO applications to access your accounts with social media websites and services that are owned and/or controlled by third parties (including, without limitation, Facebook and Twitter) (such Websites and services, collectively, the "Social Media Services"). AGOREO applications require access to your accounts with Social Media Services in order to post content and provide reporting data. When you elect to permit the AGOREO services to have access to your accounts with the Social Media Services, you will be authorizing the sharing of your information (which will include personal information if you elect to share such information) with those Social Media Services. It is important to note that the information that you share with the Social Media Services will be governed by the privacy policies and terms of service of the providers of such Social Media Services and not by AGOREO policies and agreements. You may also be able to modify your privacy settings with these Social Media Services to, for example, control what information the Social Media Services disclose to other entities, including AGOREO. When you authorize the AGOREO service to exchange information with the Social Media Services we will collect relevant information necessary to enable our website and service to access that Social Media Service, however you will provide your login information, like your password, directly to such Social Media Service (and not to AGOREO). As part of such integration, the Social Media Service will provide AGOREO with access to certain information that you have provided to such Social Media Service, and we will use, store and disclose such information in accordance with this Privacy Policy and, if and to the extent applicable, the policies of such Social Media Services. However, please remember that the manner in which Social Media Services use, store and disclose your information is governed by the policies of the applicable Social Media Services provider, and, as a result, AGOREO shall not have liability nor any responsibility for the privacy practices or other actions of Social Media Services that may be enabled within and/or otherwise accessible through the AGOREO website(s) and/or services. In addition, from time to time, our customers may offer certain contests, promotions and other offerings that will be integrated with various Social Media Services. In order to participate in these contests, promotions and other offerings, you will need to opt-in to share your Social Media Services contact information with our customers and their service providers.



GENERAL PROVISIONS


ENFORCEMENT OF THIS POLICY

AGOREO will conduct internal compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that AGOREO determines is in violation of this policy will be subject to disciplinary action, up to and including termination of employment.


DISPUTE RESOLUTION - EXTERNAL RECOURSE

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the address given below. AGOREO will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information by reference to the principles contained in this Policy.



CONTACT INFORMATION


Questions or comments regarding this Policy should be submitted to AGOREO Office by mail to:
Information Security
Agoreo, llc
6520, LoneTree Blvd, Suite 1008
Rocklin, CA 95765

CHANGES TO PRIVACY POLICY


Changes to this Policy will be posted in this section. This way you will always have a clear understanding of what information is collected online and offline, how it is used, and the choices you have.


EFFECTIVE DATE: January, 2015