Privacy Policy

Last Updated: June 8, 2020

Effective: June 8, 2020

This Privacy Policy describes how Cambridge Blockchain, in providing Tracelinks Monitor (“Monitor”) services, collects, uses and discloses information, and what choices you have with respect to the information.

1. Applicability of this Privacy Policy

This Privacy Policy applies to Cambridge Blockchain's Monitor online workplace health safety management tools and platform (collectively referred to as the “Services”), including any associated mobile and desktop applications (collectively, the "Apps"), tracelinks.co and other Tracelinks websites (collectively, the "Websites") and other interactions (e.g. customer service inquiries) that you may have with Cambridge Blockchain in regards to the Services. If you do not agree with the terms, do not access or use the Services, Apps, Websites or any other aspect of Cambridge Blockchain’s Monitor-related business.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Tracelinks platform (“Third Party Services”), or any other third-party products, services or businesses. 

In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of any data (such as messages, files or other content) submitted through Services accounts (collectively, “Customer Data”). The organization (e.g., your employer or its authorized representatives) that entered into the Customer Agreement (“Customer”) controls its instance of the Services and any associated Customer Data. If you have any questions about related policies and privacy practices, please contact the Customer whose Account (“Customer Account”) you use. If you have received an invitation to join an Account but have not yet created an affiliated user account (“User Account”), should you need any assistance please contact the Customer that sent the invitation.

2. Information we collect and receive

The Services may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

  • Customer Data. Customers or individuals granted access to an Account by a Customer (“Authorized Users”) routinely submit Customer Data as instructed by the Customer to Cambridge Blockchain when using the Services.

    If you have any questions about related policies and privacy practices, please contact the Customer whose Account you use. Authorized Users have the opportunity to review the data requested by the Customer, the Customer’s policies governing the use of this data and provide/revoke your consent to share it when you create your affiliated account or any time after.

     

  • Other Information. Cambridge Blockchain also collects, generates and/or receives Other Information:

    1. Account Information. To create or update an account, you or your Customer (e.g., your employer) supply Cambridge Blockchain with an email address, name of organization, phone number, password, and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Cambridge Blockchain (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.

    2. Usage Information.

      • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.

      • Device information. Cambridge Blockchain collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.

      • Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Cambridge Blockchain may also collect location information from devices in accordance with the consent process provided by your device.

    3. Cookie Information. Cambridge Blockchain may use cookies and similar technologies in our Websites and Services to help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.

    4. Third-Party Data. Cambridge Blockchain may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

    5. Additional Information Provided to Cambridge Blockchain. We also receive Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in a certification program or other educational program hosted by Cambridge Blockchain or a vendor, request support, interact with our social media accounts or otherwise communicate with Cambridge Blockchain.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information is not provided, we may be unable to provide the Services.

3. How we use information

Customer Data will be used by Cambridge Blockchain to provide the Services, in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Customer may, for example, use the Services to grant and remove access to Authorized Users, assign roles and configure settings, and access, modify, export, share and remove Customer Data per Customer’s policies and otherwise apply its policies to the Services.

Cambridge Blockchain uses Other Information in furtherance of our legitimate interests in operating our Services, Apps, Websites and business. More specifically, Cambridge Blockchain uses Other Information:

  • To provide, update, maintain and protect our Services, Apps, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.

  • As required by applicable law, legal process or regulation.

  • To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.

  • To develop and provide search, learning and productivity tools and additional features. Cambridge Blockchain tries to make the Services as useful as possible for Customer and Authorized Users. For example, we may make Services or Third-Party Service suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience, or create new productivity features and products.

  • To send emails and other communications. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send communications about new product features, promotional communications or other news about Monitor. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from Cambridge Blockchain regarding Tracelinks Services, please reach out through the contact mechanisms described below.

  • For billing, account management and other administrative matters. Cambridge Blockchain may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.

  • To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, Cambridge Blockchain may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

4. Data retention

Cambridge Blockchain will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Depending on how the Services are used, Customer may be able to customize and apply its retention settings. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information.

Cambridge Blockchain may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Cambridge Blockchain to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

5. How we share and disclose information

This section describes how Cambridge Blockchain may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Cambridge Blockchain does not control how they or any other third parties choose to share or disclose Information.

Customer Data is used to provide Services to the Customer. Cambridge Blockchain does not and will never share Customer Data with any other entity unless legally required to do so.

  • Customer’s Instructions. Cambridge Blockchain will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.

  • Displaying the Services. Customer Data will be displayed to the Customer in providing the Services. When an Authorized User submits Other Information, it may be displayed to the Customer. For example, an Authorized User’s email address may be displayed with their profile.

  • Customer Access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of usage activity.

  • Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with Third Party Service providers to support our common customers.

  • Corporate Affiliates. Cambridge Blockchain may share Other Information with its corporate affiliates, parents and/or subsidiaries.

  • During a Change to Cambridge Blockchain’s Business. If Cambridge Blockchain engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Cambridge Blockchain’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.

  • Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective Cambridge Blockchain customer the average usage of the Services.

  • To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process.

  • To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Cambridge Blockchain or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

  • With Consent. Cambridge Blockchain may share Other Information with third parties when we have consent to do so.

6. Security

Cambridge Blockchain takes security of data very seriously. Cambridge Blockchain works hard to protect Customer Data and Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Customer Data and Other Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, Cambridge Blockchain cannot guarantee that information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.

7. Age restrictions

To the extent prohibited by applicable law, Cambridge Blockchain does not allow use of our Services by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

8. Changes to this Privacy Policy

Cambridge Blockchain may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Cambridge Blockchain will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

9. Contacting Cambridge Blockchain

Please also feel free to contact Cambridge Blockchain if you have any questions about this Privacy Policy or Cambridge Blockchain’s practices, or if you are seeking to exercise any of your statutory rights. Cambridge Blockchain will respond within a reasonable timeframe. You may contact us at legal@cambridge-blockchain.com or at our mailing address below:

Cambridge Blockchain Inc.

Attn: Legal Department

1 Broadway, 14th Floor

Cambridge, MA 02142

USA

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