Effective Date: 8/9/2022
Prisidio provides a software platform (the “Platform”) that allows its users to store data, photographs, documents, materials, and/or other content (collectively, “User Content”) in a single online location on the Platform, access to which is controlled by the User. Each user location storing User Content on the Platform is referred to as a “Vault”, and the owner of such Vault is referred to as a “Vault Owner” or “Co-Owner”, as further described in the Terms of Service.
The Prisidio website and Services are not intended for children under the age of 18 and Prisidio does not knowingly collect any information from children under 18 years old through the Services. If the parent or guardian of a child under 18 believes that the child has provided us with any information, the parent or guardian of that child should contact us if they want this information deleted from our files.
What Information does Prisidio Collect and How is it Used?
Personal Information When you register to use the Services and create an account, the personal information we may collect includes, among other things, your name, e-mail address, location, telephone number, and your interest in specific types of products and/or services. Each time you login to the use the Services, we collect your location information. We may also collect personal information about you when another user provides us with your personal information in order to share access of the Services with you.
User Content If you are using the Services to store documents, information and data (“User Content”) in Prisidio, Prisidio will collect your User Content only in accordance with the terms of this Policy as reasonably required to provide you with access to the Services.
Website Visitor Information Like most website operators, Prisidio collects information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request when visitors use the Services. Prisidio’s purpose in collecting this information is to better understand how Prisidio’s visitors use the Services. We also gather information about your use of and experiences with our Services, including information about how you interact with the site and your sign-up experience, From time to time, Prisidio may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its Services. Prisidio also collects potentially personally identifying information like Internet Protocol (IP) addresses and may collect statistics about the behavior of visitors to the Services. For instance, Prisidio may monitor the Services to help identify spam. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
In addition to log data, we may also collect information about the device you’re using to access the Services, including the type of device, the operating system, device settings, device identifiers and crash data. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. To learn more about the information your device makes available to us, please review the policies of your device manufacturer or software provider.
Except as provided herein, we do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources you provide to us.
How we use your information
We use the information we collect to provide you full access and functionality of the Services and to protect the rights or safety of you, Prisidio or another third party. Accordingly, your information may be used for the following purposes: (i) to provide and improve our services, features and content; (ii) to administer your use of our services and accounts; (iii) to enable users to enjoy and easily navigate the Services; (iv) to better understand your needs and interests by analyzing your user and interaction with the Services; (v) to fulfill requests or to respond to questions or comments you may make; (vi) to personalize your experience; (vii) to provide you with announcements, notifications and advertisements related to your interests and use of the Services and other communications such as electronic newsletters, promotional e-mails or similar messaging; (viii) to provide service announcements; (ix) to protect against users seeking to hack into the Services; (x) to assess the level of general interest in the Services, (xi) in the case of location information, (a) to provide such information to Vault Owners or Co-Owners when a user accesses a Vault and (b) to ensure the security of the Platform; and (xii) for any other purpose with your consent. Our Services include a user data platform that organizes and directs your information to the destinations and for the uses described in this Policy.
With Whom Do We Share Your Information?
We may use and disclose without restriction non-personally identifiable aggregated information, such as website analytic data that does not include any personal information or other information that may be used to identify any of our users.
When you access a Vault, the Vault Owner and/or Co-Owner, as applicable, will receive your location information. Vault Owners and/or Co-Owners may elect to opt-out of location notifications, but such location information is gathered by Prisidio regardless of whether such location notifications are declined.
User Content Please see the Terms of Service for more information on how your User Content may be accessed and used by other Prisidio users.
Other Ways We May Share your Personal Information Other than to its employees, contractors and affiliated organizations or as described above, we disclose personally-identifying only when required to do so by law, or when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Prisidio, third parties or the public at large.
In addition, in some cases we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if Prisidio or substantially all of its assets were acquired, or in the unlikely event that Prisidio goes out of business or enters bankruptcy, user information, consisting of the User Content, would be one of the assets that is transferred or acquired by a third party to enable the Services to continue. You acknowledge that such transfers may occur, and that any acquirer of Prisidio may continue to use your personal and non-personal information only as set forth in this policy. Otherwise, we will not rent or sell potentially personally-identifying and personally-identifying information to anyone.
We may also disclose your personally-identifying information if you expressly consent to the disclosure.
We Do Not Sell Your Personal Information
Prisidio does not, to the best of our knowledge, sell or rent personal information that we have collected or retain about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling or renting of personal information because we do not engage in those practices.
Our Data Retention Criteria
Cookies are text files containing small amounts of information which are downloaded to your hard disk or to your browser's memory when you visit one of our Sites. Cookies are useful because they help arrange the content and layout of our Sites and allow us to recognize those computers or other devices that have been to our Sites before. Cookies do many different jobs, such as allowing our Sites to remember your preference settings and helping us to enhance the usability and performance of our Sites and your experience using them. Our Sites also may contain electronic images known as web beacons – sometimes called single-pixel gifs – that allow us to count the number of users who have visited specific pages. We may also include web beacons in promotional e-mail messages or newsletters in order to determine whether messages have been opened and acted upon. The type of cookie or similar technology that may be used on our Sites can be categorized as follows: Strictly Necessary, Performance, Functionality & Profile and Advertising.
- Strictly Necessary Cookies. These cookies are essential for basic functionalities of the Site, and they enable you to move around our Sites and use their features, particularly in connection with information searches and order placement. Without these cookies, services you have asked for cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet. Examples of strictly necessary cookies are a shopping basket cookie, which is used to remember the products that you wish to purchase when you add products to your shopping basket or proceed to checkout, a login/ authentication cookie which allows and manages your login to the Site and identifies you after logging in for a single session, a session cookie which is required to carry out the data transmission and provide the Site to you, a security cookie that detects repeat failed login attempts or similar abuses of the Sites. These types of cookies are regularly stored only as long as required for their purpose.
- Performance Cookies. These cookies collect information about how you use our Sites, for example which pages you go to most often and if you get any error messages from certain pages. These cookies collect information that is used to improve how our Sites work. Without these cookies we cannot learn how our Sites are performing and make relevant improvements that could better your browsing experience. Examples of performance cookies that our Sites use include cookies from Google and Adobe Analytics (see further discussion below).
- Functionality & Profile Cookies. These cookies allow our Sites to store information that you provide, such as preferences, and to store technical information useful for your interactions with our Sites. For instance, they remember your user ID and elements of your user profile. They also ensure that your experience using the Sites is relevant to you. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. These cookies will not be used to track your browsing activity on other websites. Without these cookies, a website cannot remember choices you have previously made or personalize your browsing experience. For example, we use a cookie to store your language preferences, which allows us to present you with product search results in the correct language, and we use a cookie to store your choice about the appearance of the cookie information banner that we display on our Sites. This cookie will help us remember your choice about the appearance of the cookie information banner when you subsequently visit the same site where you made your choice about the banner and any other Prisidio sites with the same domain or the same top-level domain.
- Advertising Cookies and Similar Technologies. These cookies or similar technologies may be used to deliver advertisements that are more relevant to you and your interests. They may also be used to limit the times you see an advertisement as well as help to measure the effectiveness of the advertising campaign. These cookies may track your visits to other websites. Without these cookies or other technologies, online advertisements you encounter will be less relevant to you and your interests.
Setting your cookie preference
You can usually modify your browser settings to decline cookies and you can withdraw your consent at any time by modifying the settings of your browser to reject or disable cookies or by opting out of specific cookies through the opt-out options shared below. If you choose to decline cookies altogether, you may not be able to fully experience the features of the Sites that you visit.
Our use of web analytics
We use different analytic tools which serve the purpose of measuring, analyzing and optimizing our marketing measures and provide you with customized advertisements that could be of particular interest to you. In particular, we use the following tools:
- Google Tag Manager helps to manage website tags through a single interface. The tool itself (implementing the tags) triggers other tags that may themselves collect (personal) data. However, Google Tag Manager does not access this data.
- HubSpot provides tools for social media marketing, content management, web analytics, landing pages, customer support, and search engine optimization. Prisdio has the Hubspot applications running on the Services and receives information about your usage of the Services from Hubspot.
- Facebook provides tools for social media marketing, content management, web analytics, landing pages, and search engine optimization.
- FullStory is a digital experience platform that records full browsing sessions (clicked elements, page duration data, interactions, typing, browser or device details, etc.) in order to provide us with a full picture of how our users interact with our site and allow us to optimize the user experience.
- Segment collects user events from the Services and provides a data toolkit that allows us to use data more efficiently.
Your Rights and Responsibilities
You are permitted, and hereby agree, to only provide personal information to Prisidio if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation.
You may have certain rights under applicable data protection law with respect to personal information about you that is collected through the Sites or when you contact or otherwise engage with us. To exercise any of these data privacy rights, please contact us, or have your authorized agent contact us, in accordance with the “Contact Us” section listed below. In the event you submit, or your authorized agent submits on your behalf, a data request, you (and your authorized agent) hereby acknowledge and agree, under penalty of perjury, that you are (or the authorized agent of) the consumer whose personal information is the subject of the request. We will respond to any data requests within the timeframes required by law, and we may charge a fee to facilitate your request where permitted by law.
Marketing. You have the right to opt-out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages, will give you an option of not receiving such communications from us in the future.
Privacy Rights. Residents of certain states may have additional data privacy rights, including the following:
- Access: The right to access general categories and/or the specific pieces of personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months, including the sources from which the personal information was collected; the business or commercial purpose for which your personal information was collected, used, disclosed, or sold; and, the third parties with whom we have shared your personal information.
- Deletion/Erasure: The right to request that we delete/erase your personal information under certain circumstances.
- Data Portability: The right to request that we transfer, to the extent technically feasible, personal information in certain forms and formats.
- Nondiscrimination: The right not to be subject to discrimination for asserting your rights.
To exercise any of the data privacy rights set forth herein, please contact us in accordance with the “Contact Us” section listed below. If you make, or an authorized agent on your behalf makes, any request related to your personal information, Prisidio will ascertain your identity to the degree of certainty required under applicable law before addressing your request. Prisidio may require you to match at least three pieces of personal information we have previously collected from you before granting you access or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney in compliance with applicable law. None of these rights are absolute and are subject to legal and regulatory exceptions and exemptions.
Do Not Track. Some web browsers may transmit “do-not-track” signals to the Sites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
European Union (EU) Privacy Disclaimer
Prisidio processes personal information in accordance with the legal bases set forth in the EU General Data Protection Regulation (GDPR) or EU Member State law. For example, our processing of Personal Data on individuals (as described above) is justified based on statutory provisions that (1) processing is based on the consent; (2) processing is necessary for Prisidio’s legitimate interests as set out herein; and (3) processing is necessary for the performance of a contract to which you are a party. If you are in the EU or afforded protection under the GDPR, you may have certain rights with respect to the Personal Data. To the extent permitted by applicable data protection laws, you may access the Personal Data we hold about you; request that inaccurate, outdated, or no longer necessary information be corrected, erased, or restricted; and, request that we provide your Personal Data in a standard format. You also may withdraw your consent at any time where we are relying on your consent for the processing of your Personal Data. You may object to our processing of your Personal Data where that processing is based on our legitimate interest. You have the right to lodge a complaint with your competent data protection authority. If you wish to exercise any of these rights, please contact us in accordance with the instructions provided below.
Nevada Privacy Disclaimer
Pursuant to Nevada law, a Nevada “consumer” (as the term is defined therein), may, at any time, submit a verified request through a designated request address to an “operator” directing the operator not to make any sale of his or her personal information that the operator has collected or will collect about the consumer. For clarity purposes, Prisidio does not sell or exchange your personal information for monetary consideration to a third party for the third party to license or sell the information to additional persons or parties.
Persons with Disabilities
Prisidio strives to ensure that every person has access to information related to our products and services, including this Policy. Please contact us if you would like this Policy provided in an alternative format and we will seek to meet your needs.
Links to Third-Party Websites
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.