Echo360 Online Privacy Policy

Online Privacy Policy

This Echo360 Online Privacy Policy (the “Privacy Policy”) is an integral part of the Echo360 Online Terms and Conditions (the “Terms”) and describes how Echo360 collects, uses and discloses certain information that collects related to certain information and online services that may be accessible at www.echo360.com or other Web locations where the Terms are posted (collectively, the “Echo360 Sites”) or that may be directly accessible by individual end users of our various software products through a link that we provide within those products. Capitalized terms used in this Privacy Policy have the meanings stated in the Terms unless they are defined herein. If you have objections to the Privacy Policy, you should not access or use the Echo360 Sites or our Services. This Privacy Policy does not govern privacy practices associated with offline activities or any Echo360 Web sites that are not subject to the same Terms.

Echo360 abides by the U.S.- EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the United States Department of Commerce regarding the collection, use and retention of information collected from the European Union and Switzerland. For more information about Safe Harbor go to http://www.export.gov/safeharbor/.

Changes in Privacy Policy

All “personal information” (“personal information” is defined as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains) that we collect and maintain will be subject to the version of the Privacy Policy in effect at the time of such collection. Echo360 reserves the right to change the Privacy Policy from time to time at its sole discretion, and will provide notice of material changes on the home page of the relevant Echo360 Site. If as the result of such changes, you want to alter the ways in which Echo360 is allowed to use your personal information, you can do so by following the procedure described below in the section titled “Updating your personal information and privacy preferences.” You will be deemed to have been made aware of, and will be subject to, the changes to the Privacy Policy by your continued use of the relevant Echo360 Site or Services after such notice has been posted for thirty (30) days with the following exception: If at the time you provide personal information to Echo360 you are given the opportunity (as you currently are) to limit how such information will be used to communicate with you, either by Echo360 or by third parties, Echo360 will not change your preference in this regard without your express consent. However, if Echo360 sells assets (or the assets of a division or subsidiary) to another entity, or Echo360 (or a division or subsidiary) is acquired by, or merged with, another entity, Echo360 may provide to such entity customer information that is related to that part of our business that was sold to or merged with the other entity without your consent.

Entities Collecting Personal Information

Personal information subject to this Privacy Policy is collected by Echo360, Incorporated. Echo360’s address is 21000 Atlantic Boulevard 6th Floor, Dulles, VA 20166 and its telephone number is (703) 450-7030.

The Echo360 Sites and Services may contain links to other sites at which personal information is collected. In such instances, unless expressly provided to the contrary, the collection and use of your personal information will be governed by the privacy policies applicable to those sites. Those privacy policies should identify the entity(ies) collecting your personal information.

Collection of Personal Information

As a visitor to the Echo360 Sites or user of our Services, you can engage in many activities without providing any personal information. In connection with other activities, such as downloading software or engaging in an online discussion, Echo360 may ask you to provide certain information about yourself by filling out and submitting an online form. We do not require you to engage in these activities. If you elect to engage in these activities, however, Echo360 may ask that you provide us personal information, such as your first and last name. When ordering products or services through an Echo360 Site or otherwise through our Services, you may be asked to provide a credit card number. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity. When you use an Echo360 Site or our Services, Echo360 or third parties authorized by Echo360 may also collect certain technical and routing information about your computer to facilitate your use thereof. For example, we may log environmental variables, such as browser type, operating system, CPU speed, and the Internet Protocol (“IP”) address of your computer. We use these environmental variables to facilitate and track your use of Echo360 Sites and Services. Echo360 also uses such environmental variables to measure traffic patterns upon Echo360 Sites and usage patterns of our Services. Without expressly informing you in each particular circumstance, we do not match such information with any of your personal information. When you submit personal information to Echo360 through an Echo360 Site or through the Services, you understand and agree that this information may be transferred across national boundaries and may be stored and processed in any of the countries in which Echo360 and its affiliates and subsidiaries maintain facilities, including, without limitation, the United States, Ireland and Singapore. You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage, and processing of your information may be undertaken by trusted vendors of Echo360. Such vendors are bound by contract not to use your personal information for their own purposes or provide it to any third parties. One instance where this could occur is in conjunction with framed pages in which the URL for the pages is not visible and the pages are being hosted by a vendor of Echo360. Echo360 has established relationships with service providers whose services are available to you from Echo360 Sites, through our Services (however accessed), or from Web sites that are linked to Echo360 Sites or Services. Typically, these providers offer services that Echo360 customers might find useful, such as those that can be used in conjunction with Echo360 services and products. In order to use those services, you may be required to provide personal information to the providers. Unless expressly provided to the contrary, personal information that you provide while you are visiting a provider’s Web site will be subject to the privacy policy posted on such site, and personal information that you provide while on Echo 360 Sites or while using our Services in conjunction with a provider’s service will be subject to this Privacy Policy. You should be aware that our agreements with these service providers often provide that they will share with Echo360 personal information collected from you. In such instances, Echo360 may use this information in a manner consistent with this Privacy Policy. In the situation where sites have an Echo360 “look and feel,” and you reasonably believe you are on an Echo360 Site, the site is collecting information in a solely intermediary capacity and does not use personal information for secondary purposes.

How Your Personal Information is Used

Echo360 collects your information in order to record and support your participation in the activities you select. If you subscribe to a service or register a product, for example, the information is used to register your rights, if any, to technical support or other benefits that may be made available to registered users. Echo360 may collect information, including personal information, about the use of Echo360 Sites and Services, such as the types of services used and how many users we receive daily. This information may include personal information, or it may be collected in aggregate form, without identifying any user individually. Personal information may be used or disclosed as described in this Privacy Policy, and aggregate, non-identifying statistical data may be used for any lawful purposes, including statistical analysis, marketing, or similar promotional purposes.

SPECIAL NOTICE TO EDUCATIONAL USERS

SOME OF OUR SERVICES MAY BE ACCESSIBLE BY STUDENTS, FACULTY, AND OTHER PERSONS THROUGH THE WEBSITES OPERATED BY OR ON BEHALF OF EDUCATIONAL INSTITUTIONS WITH WHICH THEY ARE AFFILIATED (THE “SCHOOL SITES,” AS FURTHER DESCRIBED IN THE TERMS). FOR EXAMPLE, OUR INSTITUTIONAL CUSTOMERS (E.G., COLLEGES AND UNIVERSITIES) MAY POST A VIDEO RECORDING OF A CLASSROOM LECTURE ON THEIR WEBSITES AND MAKE THOSE VIDEOS AVAILABLE FOR VIEWING ONLINE BY STUDENTS WHO ARE MEMBERS OF THE RELEVANT CLASSES, AND INDIVIDUAL USERS MAY BE ABLE TO ACCESS SOME OF OUR SERVICES FROM THE WEB SITE(S) WHERE THOSE VIDEOS ARE POSTED. YOU UNDERSTAND THAT, WHENEVER YOU ACCESS OUR SERVICES FROM A SCHOOL SITE, YOUR USE OF THE SERVICES IS GOVERNED BY THESE TERMS, INCLUDING, WIHTOUT LIMITATION, THIS PRIVACY POLICY, AND YOUR USE OF THE SCHOOL SITE IS SUBJECT TO WHATEVER TERMS AND CONDITIONS REQUIRED BY EDUCATIONAL INSTITUTION WHO OPERATES THAT SITE. IN ORDER TO OFFER YOU SOME SERVICES, SUCH AS ALLOWING DISCUSSION AMONG CLASS MEMBERS OR THE TAKING OF NOTES ASSOCIATED WITH A PARTICULAR RECORDED LECTURE, WE NEED TO EXCHANGE INFORMATION WITH YOUR EDUCATIONAL INSTITUTION ABOUT YOUR USAGE, AND YOU AGREE THAT WE MAY PROVIDE YOUR PERSONAL INFORMATION, INCLUDING INFORMATION ABOUT YOUR USE OF THE SERVICES, TO YOUR EDUCATIONAL INSTITUTION IN SUCH INSTANCES. YOU FURTHER AGREE THAT WE DO NOT CONTROL, AND ARE NOT RESPONSIBLE FOR, YOUR EDUCATIONAL INSTITUTION’S USE OF YOUR PERSONAL INFORMATION. SOME OF OUR SERVICES PERMIT STUDENTS TO MAKE NOTES ABOUT THEIR PARTICULAR CLASSES. WE CONSIDER THOSE NOTES TO BE YOUR PROPERTY, AND WE DO NOT PROVIDE THEM TO YOUR EDUCATIONAL INSTITUTION. HOWEVER, YOU UNDERSTAND THAT DISCUSSION GROUPS, CHAT ROOMS, AND BULLETIN BOARDS THAT MAY BE PART OF OUR SERVICES ARE NOT PRIVATE, AND ENTRIES YOU MAKE TO THOSE VENUES MAY BE ACCESSIBLE BY OTHERS.

Your Choices with Respect to Personal Information

Echo360 recognizes and appreciates the importance of responsible use of information collected on Echo360 Sites and through our Services. Without your consent, Echo360 will not communicate any information to you regarding products, services, and special offers available from Echo360, although we may find it necessary to communicate with you regarding your use of Echo360 Sites and/or Services. Except in the particular circumstances described in this Privacy Policy, Echo360 will also not provide your name to other companies or organizations without your consent. Echo360 may provide your personal information if necessary, in Echo360’s good faith judgment, to comply with laws or regulations of a governmental or regulatory body or in response to a valid subpoena, warrant, or order or to protect the rights of Echo360 or others.

Protection of Your Personal Information

The personal information that you provide in connection with registering yourself as a user of Echo360 products or services or registering an Echo360 product is classified as “Registration Information.” Registration Information is protected in several ways. Access by you to your Registration Information is available through a password and unique user ID selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone. In addition, your Registration Information resides on a secure server that only selected Echo360 personnel have access to via password. Echo360 encrypts your personal information and thereby strives to prevent unauthorized parties from viewing such information when it is transmitted to Echo360. Personal information that you provide that does not constitute Registration Information also resides on a secure server and is only accessible to selected Echo360 personnel via password. Since this information is not accessible by you, you will not be asked to select a password in order to view or modify such information. Please note that any information you post to a public bulletin board or chat room is available to all persons accessing that location. For example, your e-mail address would then be available to all persons accessing a public bulletin board.

Use of Cookies

When you visit Echo360 Sites, you can browse and access important information without revealing your identity. In order to improve those Echo360 Sites and Services, we may use “cookies” to track your usage. A cookie is a small amount of data that is transferred to your browser by a Web server and can only be read by the server that gave it to you. It functions as your identification card, and enables Echo360 to record your passwords, purchases, and preferences. It cannot be executed as code or deliver viruses. Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. (For some Web pages that require an authorization, cookies are not optional. Users choosing not to accept cookies will probably not be able to access those pages.) While Echo360 uses cookies to track your usage of Echo360 Sites and Services, and our Web servers automatically log the IP/Internet address of your computer, Echo360 does not generally use this information to identify you personally. However, if you expressly provide consent for Echo360.com to “remember” the unique identifier that you select when you register for various activities on the site, that unique identifier will be stored on a cookie on your computer, linked to your registration information, and your navigation path around the site will be tracked. We associate this data to understand how our site and services are being used so we can understand our customers and offer appropriate products and services.

Updating Your Personal Information and Privacy Preferences

We will retain your registration information for as long as your account is active or as needed to provide you services, however you have the right to access, correct or delete personal information about you that is stored by us and to set your privacy preferences about the Echo360 Sites and our Services at any time. With respect to Registration Information, this may be accomplished by linking to your account through the links made available on the relevant Echo360 Site or Services, where you can view and make changes to your personal information. You may also access, correct, or delete your personal information and privacy preferences (such as whether you wish to receive promotional communications from Echo360 or third parties) by writing or calling Echo360 at:

Echo360, Incorporated
Attn: Web Site Privacy
21000 Atlantic Boulevard 6th Floor
Dulles, VA 20166 USA
Telephone number 877.ECHO360

Please include your name, address, and/or e-mail address when you contact us.

Other than Registration Information, personal information stored by us that you have submitted through the Echo360 Sites and Services is not ordinarily accessible for review by you online. To access, correct or delete such information, you may write Echo360 at:

Echo360, Incorporated
Privacy Officer/Customer Information
21000 Atlantic Boulevard 6th Floor
Dulles, VA 20166
USA

In your correspondence, please indicate with as much detail as possible the location within the relevant Echo360 Site or Services where you provided your personal information.

Privacy-Related Inquiries and Complaints

Echo360 takes its users’ privacy concerns seriously. If you believe that Echo360 has not complied with this Online Privacy Policy with respect to your personal information or you have other related inquiries or concerns, you may write directly to the Echo360 Privacy Officer at the address indicated above.

In your letter, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that the Echo360 Online Privacy Policy has not been complied with. We will investigate your inquiry or complaint promptly.

Please note that if you provide Echo360 with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), Echo360 cannot guarantee that your most recent privacy preference will be honored.

Also, please note that Echo360 is not responsible for the content or privacy practices of non-Echo360 Web sites to which an Echo360 Site or any Services may link. You should review the privacy policy of such sites before using the sites.

If you have a complaint regarding your personal information that has not been resolved by Echo360 after contacting the Echo360 Privacy Officer, then complaints and other disputes shall be resolved by the International Centre for Dispute Resolution, (“ICDR”) a division of the American Arbitration Association (“AAA”).  Disputes brought before the ICDR will be heard under the AAA’s Commercial Arbitration Rules or the ICDR’s International Dispute Resolution Procedures.