Echo360 PolicIES

ECHO360 PRIVACY POLICY

WHAT DOES THIS PRIVACY POLICY COVER?

Echo360 respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect, use and process your Personal Data in making available our website, platform and online services that may be accessible at https://echo360.com/ (“Site”) or that may be directly accessible by you, as an individual end user of our various software services and products through a link that we provide within those services and products, and tell you about your privacy rights and how the law protects you.

Personal Data” means information about an individual (you), from which that individual is either directly identified or can be identified, and which you provide to us through the Site or otherwise, and sub-categories of Personal Data, including but not limited to: your name, company name, business address, business phone number, job title, email address, location in connection with events or activities that you may choose to participate in, or information you may request regarding our services and products.

By accessing and/or using our Site or an Echo360 service or product you consent to the collection, use, process and disclosure of your information, including your Personal Data as described in this policy.

With that in mind, this Privacy Policy is designed to describe:

  • Who we are and how to contact us.
  • Your rights relating to your Personal Data.
  • Marketing communications preferences.
  • What Personal Data we collect.
  • How we use your Personal Data and why.
  • What happens when you do not provide necessary Personal Data.
  • Who we share your Personal Data with.
  • How we keep your Personal Data secure.
  • How long we store your Personal Data.
  • End Users’ Personal Data.
  • How we use cookies and other tracking or profiling technologies.
  • Our policy on children.
  • S. California residents.
  • Third party links.

 

You may have rights under the General Data Protection Regulation 2016/679 of the European Parliament, including as implemented under the laws of the United Kingdom (GDPR), as applicable to the processing of your Personal Data provided through this Site.  The Privacy Policy is intended to meet our duties of transparency under the GDPR. 

We may revise this Privacy Policy from time-to-time and will post any modifications or changes on this page.

 

WHO WE ARE AND HOW TO CONTACT US.

Who we are.

Our company’s name is Turning Tech Intermediate, Inc., dba Echo360, aka Echo360. We are considered the Data Controller (for the purposes of the GDPR) of your Personal Data (referred to as either “Echo360”, “we”, “us” or “our” in this Privacy Policy).

How to contact us.

If you have questions regarding this Privacy Policy or wish to exercise your rights of access, rectification, erasure, restriction of processing, data portability, or objection to automated decision-making, please contact us:

By email: privacy@echo360.com; or

By mail/post to: Turning Tech Intermediate, Inc., dba Echo360, Attn: Privacy Officer/Customer Information, 265 West Federal Street, Youngstown, OH  44503, USA.

Our Data Protection Officer

The GDPR requires us to appoint a “Data Protection Officer”, this is a person who is responsible for overseeing and advising us in relation to our compliance with the GDPR (including compliance with the practices described in this Privacy Policy). If you want to contact our Data Protection Officer directly, you can email: dpo@echo360.com.

When you contact us, please describe in as much detail as possible the nature of your inquiry. We will investigate your inquiry promptly.

YOUR RIGHTS RELATING TO YOUR PERSONAL DATA.

Your rights in connection with your Personal Data

Under certain circumstances, by law you have the right to:

  • Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
  • Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

 

How to exercise your rights

If you want to exercise any of the rights described above, please contact us at privacy@echo360.com.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Complaints

 If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: privacy@echo360.com. We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority.

MARKETING COMMUNICATIONS PREFERENCES.

You can ask us to stop sending you marketing messages at any time by following the update email preferences or unsubscribe links on any marketing message sent to you or by contacting us at privacy@echo360.com.
Please note that we may still find it necessary to communicate with you regarding your use of the Site or an Echo360 product.

WHAT PERSONAL DATA WE COLLECT.

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.

Personal Data does not include ‘anonymous data’ (i.e., information where the identity of the individual has been permanently removed).  However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

 

Category of Personal Data collected

What this means

Identity Data

First name, surname, title

Contact Data

Your email address, physical address and telephone numbers.

Marketing and Communications Data

Your preferences in receiving marketing from us and your communication preferences.

Behavorial Data

Site access, page access, time spent on page, feature use and other patterns related to website flow and usage.

Technical Data

Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site or use our services.

Attendance Data

Snapshot of geolocation when used for GPS attendance and related data.

Additional Personal Data We May Collect:

  • Payment Data. If you sign up for Paid Services, we receive a portion of your payment information from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card) and we ask you to select your jurisdiction.
  • Communications Data. The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our sites is available to others. We may also collect information you share with us in connection with surveys, contests or promotions.
  • Sub-Domain Data. Information from your use of the Echo360 services or users’ sub-domains. This may include: IP addresses, preferences, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services and our Users’ sub-domains (such as timestamps, clicks, scrolling, browsing times, searches, transactions, load times, and problems you may encounter, such as loading errors).
  • Partner Information. Information we get from our partners to support our marketing initiatives, improve our services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.
  • Third-Party Services. Other information you submit to us directly or through third-party services if you use a third-party service to create an Account (based on your privacy settings with such third-party service).


Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

No Special Categories of Personal Data

 We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 


HOW WE USE YOUR PERSONAL DATA AND WHY.

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

We use the Personal Data we obtain about you to:

  • Provision of the Echo360 services and products. Create and manage your account, provide and personalize our services, process payments and respond to your inquiries.
  • Communicating with you. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your Personal Data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Echo360, you may not opt out of receiving these important notices.
  • Surveys and contests. Administer surveys, contests and other promotions.
  • Customizing the services. Provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose.
  • Improving our Services. Analyse and learn about how the services are accessed and used, evaluate and improve our services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. For example, if we learn that most users of paid services use a particular integration or feature, we might wish to expand on that integration or feature.
  • Security and Fraud Protection. To protect individuals, employees, and Echo360 and for loss prevention and to prevent fraud, including to protect individuals, employees, and Turning for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.
  • Third-party relationships. Manage our vendor and partner relationships.
  • Enforcement. Enforce our end user subscription agreement and other legal terms and policies.
  • Protection. Protect our and others’ interests, rights and property (e.g., to protect our users from abuse).
  • Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

What is our “legal basis” for processing your Personal Data? 

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

  • Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

Generally, we do not rely on your Consent as a legal basis for using your Personal Data.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.

Purpose

Category(ies) of Personal Data involved

Why do we do this

Our legal basis for this use of data

Troubleshooting

Technical Data

To track issues that might be occurring on our systems.

Legitimate Interests.

It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services. 

Marketing

·       Identity Data

·       Contact Data

·       Technical Data

To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. 

Legitimate Interests.

We have a legitimate interest in providing you with updates on our Sites and related offers or information where you have purchased or shown interest in similar services from us.

WHAT HAPPENS WHEN YOU DO NOT PROVIDE NECESSARY PERSONAL DATA?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).

In this case, we may have to stop you from using our Site and terminate the contract you have with us. We will notify you if this is the case at that time.

Personal Data from Third Party Sources

We do not collect your Personal Data from third party sources.


WHO WE SHARE YOUR PERSONAL DATA WITH.

The table below describes who we share your Personal Data with, what we share and why we share it.

Recipients

Category(ies) of Personal Data we share.

Why we share it

Location(s)

Service Providers and Business Partners

·       Identity Data

·       Contact Data 

·       Technical Data

Our service providers provide us with IT and system administration services and help us manage our customer relationships (including providing customer support, customer liaison etc).

·       Within Europe

·       The United States

Regulators and other authorities

·       Identity Data

·       Contact Data

Authorities may require reporting of processing activities in certain circumstances. We may disclose Personal Data if such disclosure is required by a valid and lawful order to a court or other governmental or public body.

·       Within Europe

·       The United States

Process payments

·       Identity Data

·       Payment Data

We transmit your Personal Data via an encrypted connection to our payment processor.

·       The United States

ECHO360 MODERN SLAVERY POLICY

Modern slavery is a crime and a violation of fundamental human rights; it includes slavery, servitude, forced labour, forced marriage, child labour violations, debt bondage, deceptive recruiting for labour or services, and human trafficking.

Echo360 is committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing systems and controls to ensure modern slavery is not present or permitted in our own business practices or across any of our controllable supply chains. Our practices and policies in this regard are guided by the United Kingdom’s Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018.

This policy applies to all persons working for Echo360 or on our behalf in any capacity, including employees, directors, officers, volunteers, interns, agents, contractors, consultants, third-party representatives, and business partners. The policy is applied to and enforced for all Echo360 business activities in all Echo360 markets.

Responsibility for the policy

Echo360 has responsibility for ensuring this policy complies with our legal and ethical obligations, and that those under our direct or indirect management comply with it.

Compliance with the policy

All persons working for Echo360 must comply with this policy. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of those working for us or under our control.

All persons are required to avoid any activity that might lead to or suggest a breach of this policy and must notify their line manager OR a company Director as soon as soon as they believe or suspect that a conflict with this policy has occurred or may occur in the future.

If any person working for Echo360 is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of Echo360’s supply chains constitute any of the various forms of modern slavery, they must raise it with Human Resources via email @ gwright@echo360.com

Communication & awareness of this policy

Internal employees will be trained on and indicate acceptance of Echo360’s policy at time of hire, with updates provided using established methods of communication between Echo360 management and employees.

External suppliers, contractors, consultants, and partners will be advised and encouraged to accept Echo360’s policy at the outset of our business relationship with them, and reinforced as appropriate thereafter.

Breaches of this policy

Any employee or external entity who breaches Echo360’s policy will face commensurate disciplinary action, which could result in dismissal or termination.

Last updated: 2022-07