Partner Portal Privacy Policy

This Privacy Statement is effective as of June 18, 2020

ColorTokens, Inc. including its affiliates, subsidiaries or assignees (“ColorTokens”, “we”, “us” or “our”) understand that our clients, Partners, Customers and other individuals (“you” or “your”) place immense trust in ColorTokens when they share data.

This Privacy Policy describes ColorTokens’ practices regarding the collection, use and disclosure of personal information of an identified or identifiable natural person (“Personal Data”) belonging to a Partner (Partners including but not limited to Distributors, Resellers, Managed Security Service Providers, System Integrators and Referrals) and Customers (Customer includes Customer entity and their authorized end users which are onboarded by Partner) processed through the use of dedicated Partner Portal (Partner Portal/Portal is a dedicated platform which manages and supports Partners to onboard potential Customers). ColorTokens is committed to processing Personal Data in compliance with applicable laws, while taking into consideration imperative interests of the Partners.

This Privacy Policy does not apply to any third-party websites, services or applications which are not directly controlled, owned, or operated by ColorTokens, even if they are accessible through our Site.

If your company has engaged ColorTokens to provide ColorTokens products and/or services (collectively, the “Services”), your company and ColorTokens have agreed to a separate agreement that, among other things, governs the use of all of the data collected and maintained by ColorTokens in connection with the operation of the Services. Unless otherwise agreed, the terms of the separate agreement between your company and ColorTokens takes precedence over the conflicting provision in this Policy.

If you have entered in an engagement to undertake business with ColorTokens, we expect that you have the highest regard for Customer specific personal information. If there is any failure on part of the Partner, the Partner will solely be liable for all damages, costs, expenses, claims arising out of breach of such information. The Partner is required to align their privacy policy with the terms set out herein and with the statutory requirements of the specific jurisdiction in which they provide services. The Partner shall inform ColorTokens of any suspicious third-party activity that may come to its notice from time to time, relating to unauthorised data usage or breach of privacy.

It is Partner’s responsibility to obtain consent from the Customer in order to process Customer Data by itself and ColorTokens per data regulations and privacy policy. For the purpose of this policy with regard to Customer Data, unless stated and agreed otherwise, Partner will be the Data Controller and ColorTokens as Data Processor.

We are not responsible for any information collected through other websites which may independently collect information from our website or Partner Portal from your comments and observations.

Information Collection & Sharing

What personal data we collect and why we collect it

Partner Portal will collect Personal Data limited to name and contact information. ColorTokens will not mandate collection of any other unnecessary information which is not relevant for the engagement of Partners under Partner Portal. By accepting this Policy you hereby agree and provide a revocable consent to process the data as required under this Privacy Policy.

Comments

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service if your email address is the same one used with the service. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the Portal, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the Portal can download and extract any location data from images on the Portal.

Contact forms

The details or information that you provide in the forms will be used strictly for communication purposes and will not be shared with any third party. The data is safe and secure, and we ensure utmost caution in protecting your data.

Cookies

If you leave a comment on our Site, you may opt-in to saving your name, email address and website in cookies. This feature is for your convenience so that you do not have to fill in your details again when leaving another comment. These cookies will last for one year.

If you have an account and you log in to this Site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no Personal Data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

Type of Cookies

Description

Managing Settings

Required cookies Required cookies enable you to navigate our Site and use its features, such as accessing secure areas of the Site.

If you have chosen to identify yourself to us, we may place a cookie on your browser that allows us to uniquely identify you when you are logged into the Site and to process your online transactions and requests.

Because required cookies are essential to operate the Site, there is no option to opt out of these cookies.
Functional cookies Functional cookies allow us to remember information you have entered or choices you make (such as your username, language and region) and provide enhanced, personalized features.

Functional cookies may also be used to improve how our Site functions and to help us provide you with more relevant communications, including marketing communications. These cookies collect information about how our Site is used, including which pages are viewed most often.

We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.

In particular, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how our Site is used, including the number of visitors, the websites from which visitors have navigated to our Site, and the pages on our Site to which visitors navigate. This information is used by us to improve our Site. ColorTokens does not upload any data that would allow Google to personally identify an individual or data that identifies a particular device.

ColorTokens may also utilize HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it.

You can manage the placement of functional cookies on your browser via your individual browser settings. Note that opting out of functional cookies may impact the functionality of our Site and degrade your user experience.

To opt out from data collection by Google Analytics, you can download and install a browser add-on, which is available here.

To learn how to control functional cookies via your individual browser settings, click here.

To learn how to manage privacy and storage settings for Flash cookies, click here

Targeting or Advertising cookies We sometimes use cookies delivered by us or by third parties to show you ads for our products that we think may interest you on devices you use and to track the performance of our advertisements. For example, these cookies collect and remember information such as which browsers have visited our Site. The information provided to third parties does not include personal data, but this information may be re-associated with personal data after the third party receives it.

ColorTokens also contracts with third-party advertising networks that collect IP addresses and other information from web beacons on our Site, from emails and on third-party websites. Advertising networks follow your online activities over time and across different websites or other online services by collecting device and usage data through automated means, including through the use of cookies. These technologies may recognize you across the different devices you use, such as a desktop or laptop computer, smartphone or tablet. Third parties use this information to provide advertisements about products and services tailored to your interests. You may see their advertisements on other websites or mobile applications on any of your devices. This process also helps us manage and track the effectiveness of our marketing efforts.

See Section 4.3, below, to learn more about these and other advertising networks and your ability to opt out of collection by certain third parties.

Embedded content from other websites

Articles on this Site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behave in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

YouTube

Our Site uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here, the YouTube server is informed about which of our pages you have visited.

If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behaviour directly with your personal profile. You can prevent this by logging out of your YouTube account.

YouTube is used to help make our Site more appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.

We do not control any third-party websites or their privacy practices. We do not endorse or make any representations about third-party websites. Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.

Google Web Fonts

For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

For this purpose, your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our plugin. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.

If your browser does not support web fonts, a standard font is used by your computer.

Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.

Analytics

We use web analytics to understand anonymous visitor demographics and behaviour data to enhance the experience. In accordance with the tools we use, we do not collect or share any personally identifiable data. If you are a logged in user on the Site, then the Site collects your behaviour data to recommend, suggest or improve your experience with the Site.

Data Sharing

We do not share or otherwise disclose Personal Data about our Partner or the Customer information shared by the Partner, except as described herein or as may be statutorily mandated. In the event it is required to disclose Partner or Customer privacy data for legal compliance or a binding regulation, ColorTokens shall notify respective Partners and Customers.

Customers before disclosing such content.

We may share Personal Data with various parties, including:

  • Our contracted service providers that process Personal Data on our behalf for IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment
  • Affiliates, subsidiaries, or assignees (collectively the “Company”) that process Personal Data for customer support, marketing, technical operations, and account management
  • ColorTokens engaged third parties such as vendors, contractors, or companies to perform services on its behalf
  • Sponsors of events, webinars, or contests for which you register
  • Third-party social media and advertising networks, which usually act as separate controllers, so that we can advertise on their platforms
  • In individual instances, professional advisers who provide consultancy, banking, legal, insurance and accounting services, or if we are involved in a merger, reorganization, asset sale or business combination
  • Public and government authorities, to the extent we are compelled to disclose Personal Data to comply with our legal obligations.

How long we retain your data

We will retain personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

What rights you have over your data

  • Request access to your Personal Data and the processing activities on the Personal Data
  • Request restriction of the processing of your Personal Data in certain circumstances
  • Request erasure of your Personal Data in certain circumstances
  • Request that your Personal Data is rectified if it is inaccurate or incomplete
  • Receive your Personal Data provided to us as a controller in a structured, commonly used, and machine-readable format in certain circumstances
  • Withdraw your consent provided at any time by contacting us

Additional information

How we protect your data

The data that we collect is completely protected, safe and secure within the Partner Portal which is compliant with security features.

What data breach procedures we have in place

The data is protected in a safe and secure platform. We ensure complete security compliance to protect the data from unauthorized access. In the event of breach, impacted Partners will be notified within stipulated time frame.

Changes to This Policy

Any Personal Data that we process is subject to this Policy. We may, however, modify and revise this Policy from time to time.

Questions?

To exercise your rights relating to your Personal Data, or if you have questions regarding our privacy practices, please contact us at [email protected] or at our mailing address below:

ColorTokens, Inc.

2101 Tasman Drive, Suite 201

Santa Clara, CA 95054

Attn: Legal

ColorTokens
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