In order to deliver personalized and relevant information to you through the App, we collect certain information from users. Please do not provide any sensitive information or health information. We do not want, nor will we ask for sensitive information. The App is not designed to process sensitive information.
Information We Collect
Information We Automatically Collect
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. If you turn cookies off, some features will be disabled, and some of the features that make the App experience more efficient may not function properly.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags) in connection with the App to, among other things, track the activities of users, help us manage content, and compile statistics about usage of the App. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Use of Your Information
We may use the information we collect from you in the following ways:
- To provide our services to you.
- To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To analyze the behavioral data you provide in the App for marketing purposes.
- To improve the App in order to better serve you.
- To contact you for marketing purposes, including to send you personalized and relevant information through email in accordance with local law and consent requirements. You may unsubscribe from our mailing lists at any time by using the “unsubscribe” feature in any marketing emails you receive from us.
- To provide customer support and to follow up with you after correspondence (live chat, email or phone inquiries).
- To comply with applicable legal obligations, including responding to a subpoena or court order.
- Where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our End User License Agreement or this Policy.
For users in the EU, we process the information we collect from you for the following lawful bases:
For the performance of our agreement with you
The information we collect may be used to provide our services to you, including to run contests; provide reports and metrics; track your goals; provide tailored customer services and support; for billing and payment purposes; and to handle your enquiries.
To comply with a legal obligation to which Sandler is subject
Any information referred to above may be used to maintain appropriate business records; comply with lawful requests by public authorities; and to comply with applicable laws and regulations; or as otherwise required by law.
For our legitimate commercial interests
Your name, contact information, information about your activities within the App, and profile and demographic information may be used to improve and develop our products and services (including the App); analyze the use of our services and generate aggregate statistics about users; personalize your experiences (e.g., for your geographic area); send or display targeted marketing; facilitate software updates; assist in security and fraud prevention; for system integrity (preventing hacking, spamming, etc.); facilitate our business operations and maintain appropriate business records; comply with our established policies and procedures; facilitate our response to legal process (e.g., a court order, warrant or subpoena); enable us to merge, sell, acquire, or transfer assets; and for other legitimate business purposes permitted by applicable law.
Use of information based on your consent
We may use information about you based on your express consent, for example to send you marketing communications.
We have put in place security measures to safeguard and secure the information we collect through the App. Nonetheless, the transmission of information via the Internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically in the App, and transmission of such data is therefore entirely at your own risk.
Disclosing Your Information
The competition aspect of the App is designed to allow users to compete against each other for daily point totals over a specific period of time. Managers can choose to create competitions for their team and decide whether or not they want to participate themselves. Users (such as yourself) can choose whether or not to participate in in the competition. Users who choose to participate will have their daily point totals accumulated within that competition, which ranks performance between all users in the competition. Managers will be able to see the activity data entered into the App by the members of his/her team with respect to the competition, but other users will only be able to see their relative performance to the competition group. A user can create and be a member of as many different competitions as they desire.
We may disclose the information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf. We take appropriate steps to ensure that such third parties treat your personal information with the same consideration that we do. We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information.
Sandler Systems, Inc. is a United States company. In accordance with local laws, we will take steps to ensure that your personal information receives an adequate level of protection as required by applicable law, such as through the use of the EU standard contractual clauses approved by the European Commission, relevant national equivalents outside the EU, or other safeguards as permissible. By providing us with your personal information, you expressly acknowledge that we may transfer your personal information to, or access it in, jurisdictions which may not provide equivalent levels of data protection to your home jurisdiction.
We may also share information in the following circumstances:
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
Special Information for California Consumers; Your California Privacy Rights
California residents may request a list of all third parties to which we have disclosed certain personal information about you for the third party’s own marketing purposes. You may make one request per calendar year. In your request, please attest that you are a California resident and provide a current California address for our response to you. We will respond to you within thirty (30) days. You may request this information in writing by contacting the Privacy Officer identified in section “Contacting Us” below.
Third-Party Web Sites and Interaction
Users Only of Legal Age of Majority
The App is designed and may only be used by those who have reached the age of majority (18 years of age in most jurisdictions). By using the App, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user’s misrepresentation of age.
Access to Information and Other User Rights
If you believe that any information we are holding about you is incorrect or incomplete, or have any complaints about the App, please inform us as soon as possible at the address below. We will respond to your request in accordance with applicable local law.
You can also update certain of your personal information by logging in in to your account. Please note that we may maintain a copy of any personal data that you have updated for a period of time as part of our backups and business records; please see the “Retention of Your Information” section below for an explanation of our retention practices.
EU users have additional rights in respect of your personal information; for example, to access or erase your personal information, object to our use of it, or require it be made available in a portable format. If these rights apply to you, and you would like to exercise them, please contact us using details set out below.
Retention of Your Information
The App applies a general rule of keeping your personal information for only as long as is required to fulfill the purposes for which it was collected. However, in some circumstances we may retain personal information for longer periods of time, for instance where we are required to do so in accordance with legal, tax or accounting obligations, or where we would like to have an accurate record of your dealings with us in the event of any complaint or challenge.
Changes to this Policy
Shannon Howell, Privacy Officer
Sandler Systems, Inc.
300 Red Brook Blvd, Suite 400
Owings Mills, MD 21117
Effective Date: December 22, 2017