Effective Date: June 3, 2019
This Policy describes our general treatment of information we receive from or about you. When you engage with different products and services we offer, we may ask you to agree to different terms and may let you know about different treatment of information specific to those products and services (“Privacy Notices”). To the extent the terms of the Privacy Notices conflict with the terms of this Policy, the Privacy Notices shall control.
If you do not agree with this Policy, do not use our products and services or provide Computable with your personal data. If you do not agree with a Privacy Notice, do not use the particular product or service associated with that Privacy Notice.
What information do we collect?
We collect your personal data and other information when you download the Application(s), access our services online, take part in campaigns or research, or otherwise interact with the Computable platform. This includes information collected when you:
Activate our products and services
Computable products and services may require electronic activation, where your device and application type, as well as unique device, application, network and subscription identifiers are sent to Computable.
Use our products and services
When you use our products and services, information regarding your interaction with such products and services will be collected. This may include records of your geographic location, the type and settings of the device, operating system, and/or browser used, and other information about your general activity on the relevant product or service. Our separate products and services may also have separate Privacy Notices for the information specifically collected.
Access our services online
Use applications online
Our applications may contact our servers periodically, for example to check for updates or to send us information relating to service usage. Additionally, we may invite you to join voluntary product and service improvement or research programs where detailed information is collected.
Information you provide us with
When you create an account, participate in a market, request services, participate in research or campaigns or otherwise interact with us, we may ask for information such as your name, email address, phone number, street address, usernames and passwords, feedback, information relating to your devices, age, gender, and language, bank account number, credit card details and other such financial information.
We also maintain records of your consents, preferences and settings relating to, for example, location data, marketing and sharing of personal data.
Your transactions with us
We maintain records of your purchases, downloads, the content you have provided us with, your requests, agreements between you and Computable, the products and services provided to you, payment and delivery details, your contacts and communications and other interactions with us. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points.
Positioning and Location data
Location-based services establish location through the use of satellite, mobile, Wi-Fi, Bluetooth Low Energy (“BLE”) or other network based positioning methods. These technologies may involve exchanging your location data and unique device and mobile, Wi-Fi, Bluetooth, or other network related identifiers with Computable. We do not use this information to identify you personally without your consent.
Personal data collected might be given or sold to third parties in aggregated or pseudonymized format. You may opt-out of this but will no longer have use of the Computable App by doing so.
When you use our location based services and features, for example “Offline mode”, your location data is stored locally, and not sent to Computable.
Why do we process Personal Data?
Computable may process your personal data for the following purposes. One or more purposes may apply simultaneously.
We may share or sell your personal data in aggregated or pseudonymized format (i.e., as data points linked by a randomly assigned number that is not used for any other purpose) to trusted third-party organizations who will utilize the information for a range of uses.
Providing products and services
We may use your personal data to provide you with our products and services, to process your requests or as otherwise may be necessary to perform the contract between you and Computable, to ensure the functionality and security of our products and services, to identify you as well as to prevent and investigate fraud and other misuses.
Some services may require an account to help you manage your content and preferences. Depending on the service, an account creation may be either required or voluntary. Account creation requires you to provide us with basic contact details about yourself, such as name, email address, country of residence and date of birth. You may also be able to voluntarily provide more information about yourself while creating a profile, such as a photo or avatar of your choice.
Developing and managing products and services
We may use your personal data to develop and manage our products, services, customer care, sales and marketing. We may combine personal data collected in connection with your use of a particular Computable product and/or service with other personal data we may have about you, unless such personal data was collected for a purpose, where the original purpose is incompatible with this purpose.
Communicating with you
We may use your personal data to communicate with you, for example to inform you that our services have changed or to send you critical alerts and other such notices relating to our products and/or services and to contact you for customer care related purposes.
What is our legal basis for processing your Personal Data?
Our legal basis for processing your personal data is dependent on the purpose for processing and may vary as described in the Privacy Notice applicable to the product or service you are using. In general, we process your personal data under the following legal bases:
Performance of a contract
We process your personal data to perform our obligations under the Service Terms applicable to the product or service you are using, provided by us or our customers.
We process your personal data if you have consented to the processing activity. You may revoke your consent at any time. Doing so will bar us from further processing of your personal data based on your consent but will not impact the lawfulness of processing based on your consent before it was withdrawn. Some of the features of our products and services might be only available if you consent to our processing of your personal data.
We process your personal data as needed to comply with laws and regulations.
We process your personal data to further our legitimate interests, such as in connection with managing, developing, testing, securing, and in limited circumstances marketing, advertising, and making recommendations regarding our products and services. Any such processing is conducted subject to appropriate measures to protect your fundamental rights and freedoms related to your personal data, and in any event will be subject to the restrictions provided in this Policy.
How long do we retain Personal Data?
We endeavor to only collect personal data that are necessary for the purposes for which they are collected, and to retain such data for no longer than is necessary for such purposes. The length of time personal data is retained, and criteria for determining that time, are dependent on the nature of the personal data and the purpose for which it was provided. For example, your personal data related to managing your account (such as name, email address, and account content and preferences) are maintained for as long as it is retained by you within your account. Other data, such as records of your activity within the application, are typically maintained only for a short period before being anonymized or pseudonymized. You may contact the Computable Privacy Office at email@example.com to obtain additional information about retention of your personal data.
Do we share Personal Data?
We sell and share personal data to third party companies in an aggregated or pseudonymized format. You may opt-out of this but will no longer have use of the Computable App by doing so.
Your consent and social sharing services
We may share your personal data if we have your consent to do so. Some services may allow you to share your personal data with other users of the service or with other services and their users. Please consider carefully before disclosing any personal data or other information that might be accessible to other users.
Computable companies and authorized third parties
We may share your personal data with other Computable partners or authorized third parties who process personal data for Computable for the purposes described in this Policy. This may include billing through your network service provider or otherwise, delivery of your compensation, providing services including customer service, managing and analyzing consumer data, conducting research and managing marketing and other such campaigns.
These authorized third parties may be permitted to use your personal data for additional purposes. We bind them contractually, require them to act consistently with this Policy and to use appropriate security measures to protect your personal data.
International transfers of personal data
Our applications and services may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred across international borders outside the country where you use our services, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for personal data or that have different legal rules on data protection, for example, the United States of America. In such cases we ensure that there is a legal basis for such a transfer and that adequate protection for your personal data is provided as required by applicable law, for example, by using standard contractual clauses approved by the European Commission or relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures. . By accepting the terms of this Policy, you acknowledge, agree and consent to (1) the transfer to and processing of personal data on servers located outside of the country where you reside, (2) our collection and use of your personal data as described herein and in accordance with the laws of the United States that may be different and may be less protective than those in your country and (3) that you are taking a risk by using the site, our products or services. You may contact the Computable Privacy Office at firstname.lastname@example.org to obtain additional information about the safeguards we take in connection with these transfers.
We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate. We may also disclose and otherwise process your personal data in accordance with applicable law to defend Computable’s legitimate interests, for example, in legal proceedings or in connection with governmental requests and filings.
Mergers and Acquisitions
If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.
How do we address the privacy of children?
The website is not directed to children under 13, and children under 13 are not permitted to use the website. We do not knowingly collect personal data from children under 13. If you become aware that a child has provided us with personal data without parental consent, please contact the Computable Privacy Office at email@example.com. If we become aware that a child under 13 has provided us with personal data without parental consent, we will endeavor to remove such information and terminate the applicable account.
How do we address Data Quality?
We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data.
What steps are taken to safeguard Personal Data?
Privacy and security are key considerations in the creation and delivery of our products and services. We have assigned specific responsibilities to address privacy and security related matters. We enforce our internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, security and privacy engineering, training and assessments. We use commercially reasonable efforts to follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect information about you, we cannot guarantee its absolute security. We also limit access to our databases containing personal data to authorized persons having a justified need to access such information.
What are your rights?
You have a right to know what personal data we hold about you, and to access it. You have a right to have incomplete, incorrect, unnecessary or outdated personal data updated. You have the right to request that your personal data be erased, and to obtain a copy of your data in a machine-readable format. You have the right to object to or restrict processing in certain circumstances, such as where you believe the data is inaccurate or the processing activity is unlawful. You have a right to unsubscribe from direct marketing messages and to request that we stop processing your personal data for direct marketing purposes or on other compelling legal grounds. However, if you opt-out from marketing and other communications from Computable, critical alerts may still be sent to you. If you are located in a European Union member state or within the European Economic Area, you have the right to lodge a complaint about our data collection and processing activities with the supervisory authority concerned.
You may exercise your rights by contacting us or by managing your account and choices through available profile management tools on your device and our services. In some cases, especially if you wish us to delete or stop processing your personal data, this may also mean that we may not be able to continue to provide the services to you. Applicable data protection law may provide certain restrictions on the extent to which these rights may be exercised. If a restriction applies, we will respond to your request with an explanation of what action will be taken, to the extent required under applicable data protection law.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits California residents that are users of our site to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
Computable Ads. We partner with third party publishers, advertising networks and service providers to manage our ads on other sites. Our third party partners may set cookies on your device or browser to gather information about your activities on the services and other sites you visit, in order to provide you with Computable ads. For example, if you visit Computable and also use a social media platform, you may see a Computable ad in your social media newsfeed or timeline.
Opting Out. You can set your browser to not accept cookies, but this may limit your ability to use our services. We currently don’t respond to DNT:1 signals from browsers visiting our services. You can also opt out of receiving interest-based ads from certain ad networks here (or if located in the European Union, here).
Device Identifiers. We use device identifiers on Computable web and mobile applications to track, analyze and improve the performance of our services and ads.
Third Party Tags. We use and manage third party tags on the website and associated domains of www.computable.io and on Computable web and mobile applications. Third party tags may take the form of pixels or tracking snippets. We use pixels to learn how you interact with our site pages and emails, and this information helps us and our ad partners provide you with a more tailored experience. We use tracking snippets to capture data from your browser, make requests to a third party partner or set cookies on your device to store data. For example, if you see a Computable ad on a social media platform and choose to use Computable, we may use a tag to reduce the number of Computable ads you see on that platform. We use Google Tag Manager to manage our third party tag usage. This may cause other tags to be activated which may, for their part, collect data and set cookies under certain circumstances. Google Tag Manager does not store this data.
Who is the controller of your Personal Data?
Computable 832 Sansome St San Francisco, CA 94111 is the controller of your personal data.
In addition, the Computable affiliate providing the application or service may be a controller of your personal data.
In matters pertaining to Computable’s privacy practices you may contact our Data Protection Officer, Bharath Ramsundar.
832 Sansome St First Floor
San Francisco, CA 94114
Computable may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, Computable will post a notice advising of such change at the beginning of this Policy and on this site's home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy. Your continued use of the website after a revision to the Policy indicates your acceptance and agreement to the current Policy. We recommend that you periodically review the Policy to make sure you understand and are up-to-date on the information we collect and what we do with it.