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Data Privacy Policy (GDPR, CCPA)

1.0 Introduction

e-Share is a technology company headquartered in Boston, Massachusetts in the United States of America, which focuses on providing secure e-mail and file sharing services to companies that desire and/or require intra-organizational, secure collaboration capabilities.

For more information about our services, please refer to our website: https://www.e-share.us

Questions or concerns?

Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact your Information Technology department for further information.

Summary of Key Points

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

  • What personal information do we process?
    • When you are registered, by your employer, to our Services, we may process personal information depending on how you interact with the Application the choices you make, and the products and features you use.
  • Do we process any sensitive personal information?
    • We do not process sensitive personal information.
  • Do we share your information with third parties and/or will you receive information from third parties as a result of using our Application.
    • Your information will never be shared with nor will you receive unsolicited information from third parties as a result of being registered to and using the e-Share Secure Collaboration Platform.
  • Sensitive Information:
    • We do not process sensitive information.

This Privacy Policy is applicable to e-Share (“we”, “our” or “us”) as related to our services, which collectively include:

  • the use of the e-Share Secure Collaboration Platform (“Application”),
  • the use of our products and services.

This Privacy Policy sets out the essential details relating to employee data relationships with e-Share as:

  • Customer End-user of the Application (“End User”)
  • Prospective demo and proof-of-concept (POC) clients

Clients contract the use of our Application and give access to their employees and other third parties, as solely decided by the Customer, by creating user accounts for access to the Application with their email address and credentials. The Clients’ administrators grant End Users roles, which result in different permissions and access rights to the information held in the Client account. The e-Share Secure Collaboration Platform is contracted by companies to provide their employees the ability to collaborate and share documents securely across the internet. As such, e-Share’s contractual commitments align with Customer policies and privacy laws and regulations.

2.0 WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you or your employer provide to us.

We collect personal information that is voluntarily provided to us when an employee is registered with the Application.

  • full name
  • email addresses
  • usernames
  • passwords

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when the Application is used.

We automatically collect certain information when you use or navigate the Application via the Portal or plugins to your email client. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal auditing and client reporting purposes.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
  • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

3. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer Application services, for security and fraud prevention, and to comply with contract obligations to your employer and the law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  1. To protect our Services: We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

 

What legal basis do we rely on to process your information?

In Short: We only process your personal information when it is necessary to operate the Application in accordance with contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

You are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • – Consent. We may process your information if you have given permission (i.e., consent) to your employer to use your personal information for a specific purpose.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Diagnose problems and/or prevent fraudulent activities
  • Legal Obligations: We may process your information where at the request of your employer (our Customer) or where it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where it is necessary and/or required by your employer (Customer) policy or required by law to protect your vital interests or the vital interests of another person, such as situations involving potential threats to the safety of any person.

e-Share’s Representative to the European Union pursuant to Article 27 GDPR is Nicholas Stamos (nick@e-share.us).

You are located in Canada, this section applies to you.

We may process your information if you have given your employer specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally obligated under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For Customer business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

4. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the service commitments to our Customers or purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by the Customer or by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the business relationship between you and your employer or e-Share and the Customer.

When we have no ongoing legitimate business need to store or process personal information, we will delete such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process.

6. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you and your company represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@eshare.us.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your persona/ information. Changes and/or terminations to your account must be expressed through e-Share’s contracted Customers. e-Share cannot process direct requests by individual persons. All such requests must be processed by a valid Customer contact.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting the appropriate contacts within your employer (our Customer).

We will consider and act upon any request in accordance with applicable data protection laws provided that they are relayed to e-Share from the person’s employer (our Customer).

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:

https://ec.europa.eu/justice/data-protection/bodies/authorities/index en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: h!tps://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting the appropriate department within your employer. e-Share will promptly act upon such requests as they are requested by an e-Share Customer.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at privacy@e-Share.us.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your persona/ information. As e-Share’s contractual relationship and obligations are between e-Share and our customers, any inquiries or requests must be channeled through the appropriate persons within your employer (our Customer).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

  1. every individual who is in the State of California for other than a temporary or transitory purpose and
  2. every individual who is domiciled in the State of California who is outside the

State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents”.

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information. However, due to the transitive nature of e-Share’s relationship with you, any and all inquiries and requests must be directed from the e-Share Customer.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category

Examples

Collected

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

PARTIAL

B. Personal information categories listed in the California Customer Records statute

Name, contact information, education, employment, employment history, and financial information

NO

C. Protected classification characteristics under

California or federal law

Gender and date of birth

NO

D. Commercial information

Transaction information, purchase history, financial details, and payment information

NO

E. Biometric information

Fingerprints and voiceprints

NO

F. Internet or other similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

NO

G. Geolocation data

Device location (via IP Address)

YES

H. Audio, electronic, visual, thermal, olfactory, or similar information

Images and audio, video or call recordings created in connection with our business activities

NO

l. Professional or employment-related information

Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us

NO

J. Education Information

Student records and directory information

NO

K. Inferences drawn from other personal information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

NO

We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Facilitation in the delivery of our Application Services and to respond to your inquiries.

How do we use and share your personal information?

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. Such agents must also engage with the individual’s employer (our Customer). No direct inquiries or requests will be processed by e-Share without the approval and involvement of the e-Share Customer (your employer).

Will your information be shared with anyone else?

  • e-Share has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.
  • e-Share will not share nor sell personal information in the future belonging to website visitors, users, and other consumers.

10. Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

Requests for the deletion of your personal information must come formally from e-Share’s customer (your employer). If asked to delete personal information, e-Share will respect that request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) our contractual obligations to our Customer, compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Registration of users and the verification of identity is the responsibility of the e-Share Customer and their designated administrators. e-Share does not perform identity verification on its users as all users of the Secure Collaboration Platform are authorized by e-Share’s Customers. e-Share operates under the assumption that user identities have been validated by their employer (our Customer) and that all use is appropriate and compliant with e-Share and the Customer’s Acceptable Use Policies.

Other privacy rights

The following rights must be exercised with the individual’s employer (our Customer). Requests received from e-Share’s Customer will be promptly honored. Due to the nature of contractual relationship(s), e-Share can not process inquiries or requests made directly by individuals to e-Share. Your rights are as follows:

  • You may object to the processing of your personal information.
  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify your employer either by prominently posting a notice of such changes or by directly sending your employer a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at privacy@e-Share.us or by post to:

e-Share
75 State Street
Suite 100
Boston, MA 02109 United States

e-Share’s Representative to the European Union pursuant to Article 27 GDPR is Nicholas Stamos (nick@e-share.us).

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

In Short – Through your employer. Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please consult the appropriate party within your organization (our Customer).