Effective as of 16 January 2020
Degree, Inc., doing business as Lattice, and its affiliates(collectively, “Lattice”) is committed to protecting your privacy. We have prepared this Privacy Statement to describe to you our practices regarding the personal information we collect from users of our website (the “Site”) and our online services, including the Lattice platform (the “Services”).
This Privacy Statement explains:
- What information we collect and why we collect it
- How we use that information and when we disclose it to others
- Your rights regarding that information, including how to access and update your information
- The steps we take to protect your information
This Privacy Statement applies to information that we obtain through the Site and Services. This Statement does not apply to personal information relating to Lattice’s employment-related activities.
Lattice is a US-based company that offers our Services to domestic and international business clients. As a result, information that we collect, including personal information, may be transferred to our U.S. offices to permit us to comply with our legal and contractual obligations, to provide information and services to prospective and current clients, and to perform related business activities. In addition, we may provide information to third-party service providers in the U.S. and in other countries to the extent necessary to support Lattice’s business activities, and we may access personal information collected by our customers to support the Services that we provide to our customers. As a result, personal information may be transferred to and stored on servers located in the United States and in countries different from the country in which that information was initially collected. Similarly, information we collect may be accessed by Lattice and our third-party service providers and business partners from countries other than the ones in which the information is stored.
Types of Data We Collect. We collect personal information from users for our commercial and business purposes, as described below.
(a) Information You Provide to Us.
- We may collect personal information from you, such as your first and last name, e-mail, username and password when you create an account to log in to our Services (“Account”).
- We will collect payment information necessary to complete transactions, including your name, credit card information, and billing information.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- If you have created an Account and upload any goal, project, objective information, performance reviews, peer feedback, or other materials to the Services, we will collect those materials in order to provide you the Services you request.
- If you sign up for our newsletter we will collect your email address.
- If you participate in a sweepstakes, contest or other promotion on our Services, we may ask you for your e-mail address and/or home number (to notify you if you win or not). We may also ask for first and last name, and sometimes postal address to verify your identity. In some situations we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstakes and contest that you enter.
- We also collect personal information at other points in our Services that state that personal information is being collected.
(b) Information Collected via Technology.
- Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Services, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs.
Use of Your Personal information
(a) General Use. In general, personal information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your personal information in the following ways:
- facilitate the creation of and secure your Account on our network
- identify you as a user in our system
- provide improved administration of our Services
- provide the Services you request
- improve the quality of experience when you interact with our Site and Services
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created
- send you administrative e-mail notifications, such as security or support and maintenance advisories
- respond to your inquiries related to employment opportunities or other requests
- send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Company
- better understand your needs and interests
- personalize and improve your experience
(b) Analytics. We also collect some information (ourselves or using third party services) using logging and cookies, such as IP address, which can sometimes be correlated with personal information. We use this information for the above purposes and to monitor and analyze use of the Service, for theService’s technical administration, to increase our Service’s functionality and user-friendliness, and to verify users have the authorization needed for theService to process their requests. As of the date this policy went into effect, we use Google Analytics, Segment.io, and Intercom.io.
If we use your personal information for an unrelated or new purpose, we will notify you and we will explain the legal basis that allows us to do so (and if you are a California resident, we will obtain your consent for the new use).
Disclosure of Your Personal Information. We disclose your personal information for our commercial and business purposes as described below and as described else where in this Privacy Statement.
(a) Third Party Service Providers. We use other companies, agents or contractors("Service Providers") to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods. Or, we may engageService Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service, to collect debts, and to analyze and enhance data (including data about users' interactions with our service). For example, we use Amazon’s storage service to store some of your information (you can find more information on Amazon's data security from www.amazon.com). These third parties may have access to your information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Statement. We require our ServiceProviders to agree to take reasonable steps to keep the personal information that we provide to them secure. We do not authorize them to use or disclose your personal information except in connection with providing their services
(b) Affiliates. We may share some or all of your personal information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Statement.
(c) Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or any portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or any of our assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Statement.
Your Choices Regarding Your Information. You have several choices regarding use of your personal information on our Services. Under certain circumstances, for example, where you are located in the EuropeanEconomic Area (“EEA”) or if you are a California resident, you may have certain rights relating to your personal information provided for under applicable law, including the right:
· to request access to your personal information (known as a"data subject access request" under the EU General Data ProtectionRegulation (the “GDPR), or for California residents, "the right to know"). If you are a California resident, you may be entitled to obtain the personal information about you that we collect, use, disclose and sell;
· to delete your personal information. You may be entitled to ask us to delete or remove personal data. For California residents this right applies to personal information we collected directly from you. Individuals located in the EEA may have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your personal information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request to delete for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
You have the right not to receive discriminatory treatment by the business for the exercise of the privacy rights conferred by California law.
(b) Changing or Deleting Your Personal Information. You may change any of your personal information in your Account by editing your settings within yourAccount or by sending an email to us at the address listed above. You may request deletion of your personal information by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives or backups. We may also retain your information for fraud prevention or similar purposes.
(c) Service Provider Opt Out. You can opt-out directly from some Advertising ServiceProviders and providers of Tracking Tools by using their opt-out tools. Some of these service providers, and links to their opt-out tools, are:
The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: www.google.com/policies/privacy.
(d) Industry Opt-Out Tools. Some Advertising Service Providers or providers ofTracking Tools may participate in the Network Advertising Initiative's (NAI)Opt-Out Tool (http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (DAA) ConsumerChoice Page (http://www.aboutads.info/choices/), and you can opt-out of certain services and learn more about your choices by visiting the links included there. Users in the EU can visit http://www.youronlinechoices.eu/ for more information about your choices and to opt out of participating service providers.
(e) Web Browser Controls. You can prevent the use of certain Tracking Tools, such as cookies, on a device-by-device basis using the controls in your web browser. These controls can be found in the Tools > Internet Options (or similar) menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to:
- Delete existing Tracking Tools
- Disable future Tracking Tools
- Set your browser to provide you with a warning each time a cookie or certain other Tracking Tools are being set
(f) Mobile Opt-Out. Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for Behavioral Advertising. You may also opt-out of certain TrackingTools on mobile devices by installing the DAA’s AppChoice app on your mobile device (for iTunes, visit https://itunes.apple.com/us/app/appchoices/id894822870?mt=8, for Android, visit https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en). For more information, please visit http://support.apple.com/kb/HT4228, https://support.google.com/ads/answer/2662922?hl=en or http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device, as applicable.
(g) Do Not Track Signals. Some web browsers may transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise our policy on responding to these signals.
California Online Privacy Protection ActCompliance. Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy ProtectionAct. We therefore will not distribute your personal data to outside parties without your consent.
Information for EU-Based Individuals: Lattice as Data Processor. In general, Lattice offers data processing services.Businesses that use Lattice are data controllers under the GDPR, while Lattice is the data processor. We offer a GDPR-compliant Data Protection Agreement for any customer who requires it. Please contact email@example.com to receive a copy.
Lattice does not specifically market or sell into the EU, and does not act as a data controller in our marketing or sales capacity.
Changes to This Privacy Statement. This Privacy Statement is subject to occasional revision. If we make any material changes in the way we use your personal information, we will notify existing users of our Services or others who previously shared their personal information with us by sending the man e-mail to the last e-mail address provided to us and/or by prominently posting notice of the changes on our Sites; we will notify others by prominently posting notice of the changes on our Sites. Any changes to this PrivacyStatement will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Services. Please note that at all times you are responsible for updating your personal information to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of thee-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your personal information, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Sites or Services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
Questions; Contacting Company; ReportingViolations. If you have any questions or concerns or complaints about our Privacy Statement or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or email, or use the “Contact Us”button below:
600 Battery St Floor 2.
San Francisco, CA 94111
If you are a California resident and you want to exercise your rights, or you wish for an authorized agent to make a request on your behalf, please contact us on our toll-free telephone number at 1-866-I-OPT-OUT(1-866-467-8688) and enter Service Code 771# or click on the 'Contact Us' button above.
A Note About Children.We do not intentionally gather personal information from visitors who are under the age of 16. If a child under 16submits personal information to the Company and we learn that the personal information is the information of a child under 16, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 16, please contact us at: firstname.lastname@example.org.