TRAIN by Cell Inc. Privacy Policy

 

This Privacy Policy describes the information Train by Cell Inc. and our divisions Guide by Cell, Engage by Cell and Give by Cell (collectively “GBC”) collect when an organization (“Organization/Users”) uses GBC’s cloud – based software and services (“Services.”)

 

Privacy Policy for Organization/Users Who Apply or Sign Up for a GBC Account

 

Scope and Consent

By applying or signing up for a GBC account, including through a computer or mobile device (‘device’), Organization/Users accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of Organization/Users information as described herein (including to contact Organization/Users), and for all other purposes permitted under applicable personal information privacy statutes, credit bureau reporting rules, anti-spam legislation, and consumer protection laws.

Amendment

We may amend this Privacy Policy from time to time by posting a revised version and updating the “Last Updated” date above. The revised version will be effective at the time we post it. We will provide Organization/Users with reasonable prior notice of substantial changes in how we use Organization/Users information, including by email at the email address Organization/Users provide. Where these changes would cause material detriment to Organization/Users, Organization/Users may of course cancel Organization/Users account at any time. We encourage Organization/Users to review this Privacy Policy whenever Organization/Users use our Services to stay informed about our information practices and the choices available to Organization/Users and to contact us if Organization/Users have any questions about these changes. Organization/Users continued use of our Services constitutes Organization/Users acceptance of any amendment of this Privacy Policy.

Collection of Information

Our Services can be used by a broad range of industries in connection with their products, services, activities and administrative functions, whether they are involved in government, retail, health, politics, human resources, technology or anything else. Accordingly, a broad range of information may be uploaded to or sent through our Services.

Without collecting some minimal amount of information, we may not be able to provide Organization/Users with the Services or the support Organization/Users request.

Our website and Services are not targeted or directed at children under the age of 13 and do not knowingly collect or store any personal information from children under the age of 13.

Information Organization/Users Provide

We collect and store certain information Organization/Users provide when Organization/Users apply or sign up for a GBC account and when Organization/Users provide information as part of our identity or account verification process. 

We collect information about Organization/Users, including:

The mobile phone number of individual users.  This is stored only for Organization/Users that use GBC text messaging services.  Without storing the mobile phone numbers it would be impossible for Organization/Users to send or receive text messages using the Services.  If Organization/Users cancel the contract with GBC, GBC will delete all records from its system.

Use Information. We collect information about how Organization/Users use our Services, including Organization/Users access time and Internet Protocol (‘IP’) address.

Information Collected by Cookies. The only occasion where cookies are used is an optional feature that Organization/User can turn on to capture what mobile web pages within the GBC Service a user is viewing.  Only if the feature called “Track Mobile Web Page Usage” is turned on by Organization/User will the specific mobile web pages viewed by a user be tracked.  Once this feature is turned off by Organization/User this information is deleted by GBC. 

 Information We Collect from Other Sources

We do not collect any information about Organization/Users from third parties.

Third-Party Advertising and Analytics

We do not allow third-party service providers to deliver content and advertisements in connection with our Services.

Use of Information

We may use information about Organization/Users to provide, maintain, and improve our Services, such as:

Displaying historical information in the GBC Reporting module;

Developing new products and Services;

Delivering the information and support Organization/Users request, including technical notices, security alerts, and support and administrative messages.

We may use information about Organization/Users:

To protect our rights or property or the security or integrity of our Services;

To enforce the terms of our Seller Agreement or other applicable agreements or policies;

To verify Organization/Users identity as required by anti-money laundering, anti-terrorism and security law (e.g., some of the government-issued identification numbers we collect are used for this purpose);

To investigate, detect, and prevent fraud, security breaches and other potentially prohibited or illegal activities;

To comply with any applicable law, regulation, legal process or governmental request.

Sharing of Information

We may share information about Organization/Users only as follows:

If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from tax authorities), (ii) to enforce the terms of our Seller Agreement or other applicable agreements or policies, (iii) to protect our rights or property, or the security or integrity of our Services or (iv) to protect us, Organization/Users of our Services or the public from harm or potentially prohibited or illegal activities; or

Organization/Users Choices

Personal Information

Organization/Users may access, change or correct information about Organization/Users by logging into Organization/Users GBC account at any time.

Deactivating or Deleting Organization/Users Account

If Organization/Users wish to deactivate or delete Organization/Users GBC account, Organization/Users may do so by emailing us at info@trainbycell.com or calling (415) 297-6677.  The account can be deactivated or deleted immediately with all information deleted from GBC system.

Location Information

No location information is collected.

Promotional Communications

There are no promotional communications sent to Organization/Users.

Security

We take reasonable measures, including administrative, technical and physical safeguards, to protect Organization/Users information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We hold information about Organization/Users at our off-site network operating center and at Amazon Web Services. We restrict access to personal information to those GBC employees who need to know that information in order to transmit, store or process it, who are subject to contractual confidentiality obligations consistent with this Privacy Policy and who may be disciplined or terminated if they fail to meet these obligations. Our third-party service providers store and transmit personal information in compliance with this Policy and other appropriate confidentiality and security measures.

Nevertheless, GBC cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use Organization/Users personal information for improper purposes. In the event that any information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.

The General Data Protection Regulation (GDPR)

GBC is committed to complying with the requirements of the GDPR and to protecting all personal data received from data subjects in the United Kingdom and European Union member countries in accordance with the Privacy Shield Framework’s Principles, which are aligned with the data protection requirements in the UK and EU: Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity & Purpose Limitation; Access; and Recourse, Enforcement & Liability.

Organization/Users Rights

If Organization/Users use the Services in Europe Organization/Users have the legal right under European data protection law to a copy of all the personal information that GBC holds about Organization/Users. If Organization/Users request this information from us we will provide it to Organization/Users for a fee not exceeding the amount permitted by law. As mentioned above, Organization/Users can also ask us to correct any errors in this information. Also, as referred above, Organization/Users have a right to prevent the use of Organization/Users personal information for direct marketing purposes.

 

 Contact

Please contact our Privacy Department with any questions or concerns regarding this Privacy Policy by emailing info@trainbycell.com, by calling us at (415) 297-6677 by writing to us at:


Train by Cell Inc.

Attention: David Asheim
300 Beale Street, Suite 608
San Francisco, CA 94105

 

If Organization/Users have any questions or concerns regarding our policy or if Organization/Users believe our policy or applicable laws relating to the protection of Organization/Users personal information have not been respected, Organization/Users may file a complaint with our Privacy Department listed above and we will respond to let Organization/Users know who will be handling Organization/Users matter and when Organization/Users can expect a further response. We may request additional details from Organization/Users regarding Organization/Users concerns and may need to engage or consult with other parties in order to investigate and address Organization/Users issue. We will keep records of Organization/Users request and any resolution.

Update: April, 2018