This Emburse Privacy Statement (“Privacy Statement”) describes the various ways that Emburse, Inc. for itself and on behalf of its affiliates ("Emburse" or "we" or “us” or “our”) processes information about you that is collected by Emburse in the context of sales and marketing activities and explains how Emburse uses such information for its own business purposes. As used in this Privacy Statement, “Personal Data” means any data collected through the various Emburse online, digital, electronic sites and technologies, such as public-facing sales and marketing websites, social media pages, chat features and online conversations, or HTML-formatted e-mail messages we use to pursue our sales and marketing activities and that can be used to directly or indirectly identify an individual but excluding any business applications. In this Privacy Statement, “goods and services” includes access to Emburse’s web sites, offerings, contests, sweepstakes, other content, non-marketing related newsletters, whitepapers, events, conferences, webinars and seminars.
Data Controller. When you visit the Emburse website, the data controller is the Emburse entity named in the legal disclosure page on the Website.
Links to Third Party Websites. This website may contain links to third-party (meaning non-Emburse companies) websites. Emburse is not responsible for the privacy practices or the content of such third-party websites. Therefore, we recommend that you carefully read the privacy statements of such third-party sites.
Use of Emburse Websites by Children. Emburse’s Channels are not directed to users under the age of 13. If you are younger than 13, you may not use our Channels. If you are a parent or guardian and believe we may have collected information about a child, please contact us at: firstname.lastname@example.org
WHAT INFORMATION WE AND OTHERS COLLECT FROM YOU AND HOW IT IS COLLECTED
We collect your Personal Data. We collect such Personal Data about you directly, indirectly and/or automatically as described below. To the extent permitted by applicable law, we may combine the information collected about you, as described below, including information about the organization for which you work, with other information in our possession or information that you provide to us, and we treat all this information about you as Personal Data.
Direct collection of business information and Personal Data
When you access, use and/or interact with us, we directly collect information you voluntarily provide us:
Examples of direct interactions with you where you provide us business information and Personal Data about you include the following:
Indirect collection of business information and Personal Data
We also obtain business information and Personal Data about you from third party sources, as permitted by applicable law, such as the following:
When the data protection laws applicable in the EEA apply to you, in the instances listed above, we shall provide you with the information required by law within the prescribed timeframe (including the name, legal form and address of the source of your Personal Data).
Automatic collection of business information and Personal Data
When you access, use and/or interact with us through a digital channel, you do so using a “Device,” which is either a personal computer, desktop or laptop, or a mobile device such as a smartphone or a tablet. A “Device Identifier” is the number that is automatically assigned to the Device you use to access the digital Channel, and we may identify your Device through its Device Identifier. The “Tracking Technologies” are the various technologies we use to automatically collect Device Identifiers and other information about you, more precisely the following information:
The information collected through Tracking Technologies may be considered Personal Data under applicable data protection laws. For additional information about our use of Tracking Technologies, please see below in How We Follow Visits and Usage (Cookies and Analytics).
HOW YOUR INFORMATION IS USED AND PROCESSED
Legal Basis for Processing. We collect and process your Personal Data with your consent or as permitted under applicable data protection laws to provide the goods and services you use on the Channels, fulfill your inquiry, operate our business, meet our contractual and legal obligations, ensure compliance, protect the security of our systems and our customers, or fulfil other legitimate interests.
Freely Given Personal Data or Consent. As a general principle, granting your consent and providing business information and Personal Data about you is entirely voluntarily and there are no adverse consequences to you if you do not grant a consent when required under applicable law or do not provide the required information. However, there are circumstances where Emburse cannot take action without certain Personal Data because such information is required, such as to process your orders or provide you with access to a web offering or newsletter. In these cases, without the relevant Personal Data, Emburse will not be able to provide you with what you requested.
Purposes of Processing. We use and process Personal Data about you for purposes described below:
HOW WE FOLLOW VISITS AND USAGE (COOKIES AND ANALYTICS)
We may use Tracking Technologies such as cookies, beacons, tags and scripts which are used in analyzing trends, administering the website, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Local Storage Objects (HTML 5)
We use Local Storage Objects (LSOs) such as HTML5 to store content information and preferences. Various browsers may offer their own management tools for removing HTML5 LSOs.
Behavioral Targeting / Re-Targeting
Managing Preferences. You have the right to accept or reject cookies and can access and/or change your cookie preference or opt-out of third party analytics or opt-out of receiving interest-based advertising from Emburse at any time. Network Advertising Initiative and other similar providers offer information about some of the Internet advertising companies we may use, including how to opt-out of interest based advertising they deliver. Please follow the instructions provided by YourOnlineChoices https://youronlinechoices.eu/ (EU), the Network Advertising Initiative https://thenai.org/opt-out/ (US) and the Digital Advertising Alliance https://youradchoices.com/control (US), Digital Advertising Alliance of Canada https://youradchoices.ca/en/learn (Canada), Data Driven Advertising Initiative http://www.ddai.info/optout (Japan) or other similar services. To opt-out of Google Analytics web tracking you can download Google Analytics Opt-out Browser Add-on.
In addition to what is specified in this Privacy Statement, you can manage preferences for Cookies directly from within your own browser. It is also possible to delete Cookies installed in the past through browser preferences, including the Cookies that may have saved the initial consent for the installation of Cookies by this website. Information about how to manage Cookies in the most commonly used browsers can be found at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari, and Microsoft Internet Explorer.
For additional information on managing cookies, please see below in “WHAT PRIVACY CHOICES AND CHANGES ARE AVAILABLE TO YOU.”
HOW YOUR INFORMATION IS SHARED
We work with affiliated and third party vendors, consultants and other service providers that help us run our sales and marketing activities. These companies provide work and services such as email delivery, postal delivery, collecting business information and Personal Data about you on our behalf, event/campaign registration and management, information technology and related infrastructure services, data analysis and insight, auditing and other similar services. In some cases, these companies need access to some of your Personal Data to carry out their work for us. They are not permitted to use your Personal Data for their own promotional or business purposes.
Based on your consent, (where legally required), we may share your contact information with sponsors, co-sponsors and/or exhibitors of events and/or conferences organized and hosted by Emburse for their own marketing and promotional purposes. Please note that our sponsors, co-sponsors and/or exhibitors may directly request your information at their conference booths or presentations. You should review their privacy policies to learn how they use personal information.
If you register for an event, seminar, webinar or conference of Emburse, based on your consent we may share basic participant information such as your name, company and email address with other participants of the same event, seminar, webinar or conference to foster the communication and exchange of ideas.
We may also share your information in the following circumstances:
HOW YOUR INFORMATION IS KEPT SAFE
Emburse maintains data handling and storage practices and procedures that are designed to promote the integrity and confidentiality of Personal Data. We update and test our security technology on an ongoing basis. We use commercially acceptable means to protect your Personal Data in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction, but we cannot guarantee its absolute security.
HOW YOUR INFORMATION IS TRANSFERRED INTERNATIONALLY
As part of a global group of companies, Emburse has affiliates and third-party service providers within, as well as outside of, the EEA. Therefore, your Personal Data may be transferred, used, processed or stored in the United States or any other country where Emburse operates, including jurisdictions that may not have data privacy laws that provide protections equivalent to those provided in your home country. We take steps designed to ensure that the Personal Data we collect under this Privacy Statement is processed according to the provisions of this Privacy Statement and applicable law wherever the data is located. By providing your information to us, you agree to that transfer, storage, and processing in the United States and other countries outside of the European Union. Also, we may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our digital channels. When we transfer Personal Data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection, such transfer is based on the Standard Contractual Clauses (according to EU Commission Decision 87/2010/EC or any future replacement) or other acceptable mechanism in order to contractually ensure that your Personal Data is subject to a level of data protection which applies within the EEA or other permitted mechanism. You may gain information regarding such transfer by sending a request to email@example.com.
HOW YOUR INFORMATION IS STORED AND RETAINED
We store and retain your Personal Data for as long as necessary to fulfill the purposes described in this Privacy Statement. For clarity, in circumstances where we are required by law to retain your Personal Data longer, such as for tax, legal, accounting or other purposes, or where we need your Personal Data to assert or defend against legal claims, we will retain such information until the end of the relevant retention period or the resolution of such claim.
WHAT PRIVACY CHOICES AND CHANGES ARE AVAILABLE TO YOU
You can unsubscribe from promotional emails by: (1) following the unsubscribe instructions in our emails; or (2) emailing us at firstname.lastname@example.org. You can subscribe to or unsubscribe from Emburse e-mail communications in the Emburse Preference Center. If you have any problems using any of these opt-out mechanisms, please contact us at email@example.com. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with transactional information related to the goods and services you have ordered or requested on the Channels.
Where required by applicable laws, you can opt out of cookies that are not required to enable core site functionality and can manage your cookie preferences via the link on the website. If you are a US resident, please be aware that we may not recognize or respond to every type of “do not track” signal or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services, but we give you certain choices about how we collect Personal Data as described in this Privacy Statement. Please see “Managing Preferences” under the “HOW WE FOLLOW VISITS AND USAGE, WHY AND HOW YOU KEEP CONTROL.” Remember, if you delete your cookies, or use a different browser or computer, you will need to set your cookies preferences again. If you have any problems regarding cookies, please contact us at firstname.lastname@example.org.
YOUR EUROPEAN PRIVACY RIGHTS
If required by applicable law, we adhere to the following rights described below.
If you wish to exercise any data protection and privacy right that is available to you, we will process your request in accordance with applicable data protection laws. We may need to retain certain information for record-keeping purposes and/or to complete transactions that you began prior to requesting any deletion.
If you would like to exercise any of the above rights, please contact email@example.com so that we may consider your request under applicable law, verify any relevant legal requirements and exemptions, including steps to verify your identity before complying with the request.
YOUR CALIFORNIA PRIVACY RIGHTS
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
For more details about the personal information collect, including the categories of sources, please see the What Information We Collect section above. We collect this information for the business and commercial purposes described in the How Your Information is Used section above. We share this information with the categories of third parties described in the How Your Information is Shared section above. Emburse does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in the How We Follow Your Visits and Usage section above.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at firstname.lastname@example.org. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
CHANGES TO THIS PRIVACY STATEMENT
We may update this Privacy Statement from time to time without notice to you other than posting the revised Privacy Statement on the Channels or by providing such notice about or obtaining consent to changes as may be required by applicable law. If we change our Privacy Statement, we will post those changes to this Privacy Statement and change the "last updated" date above. We encourage you to periodically review this Privacy Statement for the latest information on our privacy practices.
Notwithstanding the right you may have to lodge a complaint as stated about “Your European Privacy Rights”, if you have any questions about this Privacy Statement or to file any complaint regarding this Privacy Statement, please contact us at email@example.com.
Emburse will investigate and attempt to resolve complaints and disputes regarding the collection, use, and disclosure of Personal Data by referencing the privacy principles stated in this Privacy Statement.