Ginko Solutions - Providing Web and Software Solutions with Educational Learning Resources

PRIVACY POLICY

Last Updated on December 23, 2019

Introduction

This Privacy Policy is designed to help you understand (i) what information we collect from visitors to our websites or through our marketing channels; (ii) how we use such information at Ginko Solutions, and (iii) the choices you have associated with that information.

When we refer to "Ginko Solutions," "we," "our," or "us" in this policy, we are referring to Ginko Solutions, Inc., and its subsidiaries and affiliates, as the "controller" (and/or a "business" under the CCPA) or the equivalent legal construct under applicable law of the information we process when you visit our websites and/or we interact with you through our marketing channels for business purposes. This Privacy Policy covers the digital properties listed here. When we refer to "personal information" in this policy, we are referring to personal data, personally identifiable information, or the equivalent of each under applicable law.

It is important to note that where Ginko Solutions handles personal information on behalf of or at the direction of its customers through their use of our Services, Ginko Solutions is the "processor" (and/or "service provider" under the CCPA) or the equivalent legal construct under applicable law of that data and Ginko Solutions’s use, processing, and handling of such data is done pursuant to the written instructions of its customers in the form of the Terms of Service, Data Processing Addendum, and/or any similar written agreement between the parties. In these cases, our use of information collected through our Service shall be limited to the purpose of providing and operating the Services for our customers. As used herein, the "Service(s)" refers to the applications, services, and websites (marketing and product) provided by Ginko Solutions. Ginko Solutions may, from time-to-time, introduce new products and services. To the extent that any new products and/or services affect this Privacy Policy, we will notify you as further described in Section 8 below.

If you have any questions about this privacy policy or our practices, please contact us. If you are in the European Union, you may contact our Data Protection Officer through this same email address.

Contents:

Personal Information
Application Data
Usage Data
Information We Collect and Receive
How We Use the Information We Collect and Receive
Analytics, Cookies and Other Web Site Technologies
Information Sharing
Communicating
Data Location and Retention
Your Rights and Choices
Security
International Data Transfers
Children's Privacy
Changes to this Statement/Contact Us

Personal Information
You provide personally identifiable information when you sign up for our service. When you sign up via a third-party authentication provider (like Google or Dropbox), our service retrieves and saves some information about you from the provider. The specific information is controlled by the authentication provider and by the permissions you approve when you sign up. In particular, our service retrieves your email address.

In addition to the information we collect when you sign up, you may voluntarily provide us with additional personal information. For example: Your place of employment, when you complete a sales form on our website.

Addresses, telephone numbers, additional email addresses, and other personally identifiable information you provide to us through any sales and marketing forms available on our website. This type of information helps us improve our business relationship with you.

Your personally identifiable information will not be sold or rented to third parties in a way that identifies you as an individual. In the event that we are acquired by another company, your personally identifiable information may be part of the assets transferred to the acquiring party.

Application Data
Our API Client uses YouTube API Services. You can learn more about the associated Google Privacy Policy at: http://www.google.com/policies/privacy.
By using our API client, you are agreeing to be bound by YouTube's Terms of Services.
You can revoke our client's access to your Google account at anytime via the Google Security Settings page here: https://myaccount.google.com/security

The data that your applications collect and use reside in a third-party storage provider (e.g., Google Accounts, YouTube Accounts, Dropbox, etc.). Our service does not persist this data. However, in order to improve performance, we may temporarily cache data, images, and other files.

In order to interact with your data, our service maintains authentication (OAuth) tokens that allow our software to act "on your behalf" to read and write data to Google/YouTube. These tokens are securely stored along with your personal information.

Usage Data
Our service uses browser session cookies and browser local storage to maintain user session state. This helps to speed up user login. You can set your browser to disable cookies and local storage, but this will significantly compromise or disable product usability.

Our service logs usage information in encrypted log files, including the features you accessed on our site and standard browser-provided information. We use this information not only to debug issues and problems, but also to learn aggregated patterns across all our users and thereby improve our service.

Our service may send notifications via email and other notification mechanisms. We may employ clear images to track the effectiveness of our emails.

1. Information We Collect and Receive
We collect several different types of information, including:

Customer Account and Registration Data: This includes information you provide to create your account with us or register for events, webinars, surveys, etc. and may include, first and last name, billing information, a password and a valid email address.

Service Data (including Session and Usage data): When you visit our websites and use our Services, we receive information either voluntarily entered by you or others (for example, schedules, attendee info, etc.), or passively logged by the website or Service itself, (for example, duration of session, use of webcams, connection information, etc.). We may also collect usage and log data about how the Services are accessed and used, including information about the device you are using to access the Services, IP addresses, location information, language settings, what operating system you are using, unique device identifiers and other diagnostic data to help us support and improve upon the Services.

Third Party Data: We may receive information about you from other sources, including publicly available databases or from third parties from whom we have purchased data, and combine this data with information we already have about you. We may also receive information from other affiliated companies that are a part of our corporate group. This third-party data is obtained for our legitimate business interests and helps us to update, expand and analyze our records, identify new prospects for marketing, and provide products and services that may be of interest to you.

Location Information: We collect your location-based information for the purpose of providing and supporting the Service and for fraud prevention and security monitoring. If you wish to opt-out of the collection and use of your collection information, you may do so by disabling location services on your mobile device.

Device Information: When you use our online and mobile Services, we may automatically collect information about the type of device you use, for example, the operating system version or the device identifier (or "UDID").

2. How We Use the Information We Collect and Receive

Ginko Solutions may access and use the data we collect as necessary: (a) to provide and operate Services; (b) to address and respond to service, security, and customer support issues; (c) to detect, prevent, or otherwise address fraud, security, unlawful, or technical issues; (d) as required by law; (e) to fulfill our contracts; (f) to improve and enhance the Services; and/or (g) to provide analysis or valuable information back to our customers and users.

Some specific examples of how we use the information:

Create and administer your account
Send you an order confirmation
Facilitate and improve the usage of the Services you have ordered
Assess the needs of your business to determine suitable products
Send you product updates, marketing communication, and service information
Respond to customer inquiries and support requests
Conduct research and analysis
Display content based upon your interests
Analyze data, including through automated systems and machine learning to improve our Services and/or your experience
Provide you information about your use of the Services and benchmarks, insights and suggestions for improvements
Ginko Solutions also collects and stores meeting attendee information to fulfill our obligation to our customers and provide the Services. With their consent or under their instructions, we may also directly provide product and other Ginko Solutions related information to attendees. Ginko Solutions will retain your information, under a lawful basis, as long as your account with us is active, to comply with our legal obligations, to resolve disputes, and enforce our agreements.

If you wish to cancel your account or for us to stop providing you Services, or if we hold personal information about you and you want it to be removed from our database or de-activated, please contact us here.

3. Analytics, Cookies and Other Web Site Technologies

Ginko Solutions continuously improves its websites and Services through the use of various third-party web analytics tools, which help Ginko Solutions understand how its visitors use its websites, desktop tools, and mobile applications, what they like and dislike, and where they may have run into problems which need to be addressed.

Tracking Technologies:

Ginko Solutions and our partners use cookies and similar tracking technologies to track user traffic patterns and hold certain registration information. Other tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyze our Services. If you wish to not have the information these technologies collect used for the purpose of serving you targeted ads, you may opt-out here, or if located in the European Union, click here. The Help Menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can still review the website if you choose to set your browser to refuse all cookies; however, you must enable cookies to establish an account and to install the Services. To manage Flash Cookies, please click here.

Examples of Cookies We Use:

Cookie Type

Purpose

Description

Session Cookies

We use these cookies to operate our websites.

Some cookies are essential for the operation of Ginko Solutions websites. If a user chooses to disable these cookies, the user will not be able to access all of the content and features.

Preference Cookies

We use these cookies to remember your preferences.

When you register at a Ginko Solutions website, we use cookies to store unique, randomly assigned user IDs that we generate for administrative purposes. These cookies enable you to enter the Ginko Solutions sites without having to log on each time.

Advertising Cookies

These cookies are used to serve you with advertisements that may be relevant to you and your interests.

We use cookies to make advertising more engaging to users, as well as to assist in reporting on marketing program performance and analytics.

Security Cookies

These cookies are used for general security purposes and user authentication.

We use security cookies to authenticate users, prevent fraudulent use of login credentials, and protect user data from access by unauthorized parties.

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
Social Media: Our sites include social media features, such as Facebook, Google and Twitter "share" buttons. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These services will also authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form or provide feedback. Your interactions with these features are governed by the Privacy Policy of the third-party company providing them.

4. Information Sharing

Ensuring your privacy is important to us. We do not share your personal information with third parties except as described in this Privacy Policy. We may share your personal information with: (a) third party service providers; (b) business partners; (c) affiliated companies within our corporate structure; and (d) as needed for legal purposes. Third-party service providers have access to personal information only as needed to perform their functions and they must process the personal information in accordance with this Privacy Policy. These transfers to subsequent third parties are covered by appropriate transfer agreements such as the EU Model Clauses.

Examples of how we may share information with service providers include:

Fulfilling orders and providing the Services
Payment processing and fraud prevention
Providing customer support
Sending marketing communications
Conducting research and analysis
Providing cloud computing infrastructure
Examples of how we may disclose data for legal reasons include:

As part of a merger, sale of company assets, financing or acquisition of all or a portion of our business by another company where customer information will be one of the transferred assets.
As required by law, for example, to comply with a valid subpoena or other legal process; when we believe in good faith that disclosure is necessary to protect our rights, or to protect your safety (or the safety of others); to investigate fraud; or to respond to a government request.
5. Communicating

Ginko Solutions may need to communicate with you for a variety of different reasons, including:

Responding to your questions and requests. If you contact us with a problem or question, we will use your information to respond.
Sending you important transactional and/or administrative emails and messages about Services that you use. We may contact you to inform you about changes in our Services, our Service offerings, and important Service-related notices, such as billing, security and fraud notices. These emails and messages are considered a necessary part of the Services and you may not opt-out of them.
Sending emails about Ginko Solutions news or products that we think you’d like to hear about either from us or our business partners, in each case, under a legitimate business interest and/or based upon your request. If you are not interested in receiving these communications, you can always opt out of these types of messages at any time by clicking the unsubscribe link at the bottom of each communication or by following the instructions at Section 7 and/or Section 12 of this Privacy Policy.
Conducting surveys. We may use the information gathered in the surveys to enhance and personalize our products, Services, and websites.
Offering referral programs and incentives, which allow you to utilize email, text, or URL links that you can share with friends or colleagues.
6. Data Location and Retention

We only retain a limited amount of personal data, under an appropriate and lawful basis, for as long as needed for the business purposes for which they were collected or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. After that time frame, we delete or anonymize the data according to our data retention policies and/or procedures.

7. Your Rights and Choices

Our customers can always review, update or change personal information from within their account or by contacting us. Ginko Solutions will also, when you request, provide you with information about the types of information we process about you and whether we hold, or process on behalf of a third party, any of your personal information. You may have the right to a copy of your personal information in machine-readable format.

You can also ask about:

whether and why we have your personal information;
how we obtained your personal information;
what we have done with your personal information;
to whom we have communicated your personal information;
where your personal information has been stored, processed or transferred;
how long we will retain your personal information or how that retention period will be determined; and
the safeguards in place to protect your information when it is transferred to third parties or third countries.
Finally, you can ask us: (a) not to collect or use your personal information for certain purposes; (b) to delete your personal information; or (c) to provide your personal information to a third party.

To make any of these requests, please contact us at https://support.Ginko Solutionsinc.com/contactus which allows you to make a request online or through a phone call.

We may also collect information on behalf of our customers, to provide the Services, and we may not have a direct relationship with the individuals whose personal data is processed. If you are a customer or end-user of one of our customers, please contact them (as the data controller or legal equivalent) directly with any of these requests.

Depending on which laws apply to your personal information, we may only be able to fulfill some of the above requests for you. If you make a request and we have a justified lawful reason to maintain your information (e.g., legal and audit purposes), we will explain your legal rights, the reason we are maintaining such information and, if applicable, any recourse you may have.

We will respond to your request without undue delay, but in any event within thirty (30) days. We reserve the right to take reasonable steps to verify your identity prior to granting access or processing changes or corrections.

If you wish to no longer receive marketing communications from us, you can opt-out of marketing by clicking on the unsubscribe link on any marketing email you receive, or http://solutions.Ginko Solutions.com/unsubscribe. Note that if you are a LastPass user, please visit https://lp.Ginko Solutionsinc.com/unsubscribe to opt-out.

You may also have the right to complain to a regulatory authority. If you have a question or complaint, we ask that you please contact us first. If you are in the EU and we are unable to resolve your complaint, you may complain to the Data Protection Authority in your home country.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

EU-U.S. and Swiss Privacy Shield

TRUSTe
Ginko Solutions has self-certified to the EU-U.S. Privacy Shield and Swiss Privacy Shield with respect to Customer Data. For more information, see our Privacy Shield Notice.

8. Security

Ginko Solutions follows generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. However, no security measure is perfect. We recommend safeguarding your password, as it is one of the easiest ways you can manage the security of your own account – remember that if you lose control over your password, you may lose control over your personal information.

9. International Data Transfers

Ginko Solutions is headquartered in the United States of America and maintains a global infrastructure. Information that we collect and maintain may be transferred to, or controlled and processed in, the United States and/or other countries around the world. Although these countries may have different data protection laws to the laws of your country, we will protect the privacy and security of personal information we collect in accordance with this Privacy Policy, regardless of where it is processed or stored. Where Ginko Solutions processes European Union personal information outside of the European Union in countries not declared to have adequate protections, it does so in compliance with Chapter 5 of the GDPR (e.g., under the E.U.-US and Swiss Privacy Shield Framework(s) and/or Standard Contractual Clauses) and applicable law.

To learn more about the locations where Ginko Solutions may process your personal information through its affiliated companies or third-party Sub-processors (when Ginko Solutions acts as a data processor, service provider, and/or the applicable legal equivalent), please visit the Product Resources section of the Ginko Solutions Trust & Privacy Center.

10. California Privacy Rights

California Consumer Privacy Act

Additionally, the California Consumer Privacy Act, or CCPA, which takes effect on January 1, 2020, is intended to provide California residents with expanded rights to access, delete and control their personal information. Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.

For personal information collected by us during the preceding twelve (12) months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information. We will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you access to our Services, charge you different prices for Services or provide you a different level or quality of Services.

The CCPA additionally requires businesses to provide or make available certain disclosures in the event a party sells your personal information to third parties, however because Ginko Solutions does not receive any personal information as consideration for any Services or other items provided or performed by Ginko Solutions, these disclosures do not apply. Ginko Solutions does not collect, retain, share or use any personal information except as necessary for a business purpose pursuant to a written contract (i.e., to provide and operate the Services) and subject to the restrictions specified in Section 1798.140 (v) of the CCPA. Additionally, Ginko Solutions refrains from taking any action that would cause any transfers of personal information that qualify as "selling personal information" under the CCPA or other similar applicable privacy laws.

California residents may exercise the rights specified in this Privacy Policy or request information from us regarding whether we share certain categories of your personal information with third parties by contacting privacy@Ginko Solutions.com.

California Shine the Light

Residents of the State of California, under California Civil Code § 1798.83, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.

Ginko Solutions qualifies for the alternative option. We have a comprehensive privacy statement and provide you with details on how you may either opt-out or opt-in to the use of your personal information by third parties for direct marketing purposes. Therefore, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year.