Traverse Systems Business Portal Privacy Statement
Traverse Systems LLC (“Traverse Systems”) knows that you care about how your personal and business information is used and shared, and we take your privacy seriously. Traverse Systems has created this privacy statement (“Statement”) in order to demonstrate our commitment to your privacy. By accessing the Traverse Systems website at www.traversesystems.com, including all related pages and all linked pages managed by Traverse Systems (the “Site”) and including any subscription-based features or services offered by Traverse Systems through the Site (collectively, the “Service”), you are accepting the practices outlined in this Statement.
1. What Does This Privacy Statement Cover?
This Statement covers Traverse Systems’ collection and use of business and personal information that Traverse Systems gathers when you are on the Site and when you use the Service. This Statement does not apply to the practices of third parties that Traverse Systems does not own or control, or to individuals that Traverse Systems does not employ or manage. For avoidance of doubt, this Statement does not apply to any third-party information gathered by Traverse Systems’ subscribers (e.g., information about customers of Traverse Systems subscribers) and submitted directly by them to the Service for use in connection with their activities (but not gathered or requested by Traverse Systems) (“Third Party Data”). Traverse Systems will not review, share, distribute, print, or reference any such Third-Party Data except as provided in any Service agreement or as may be required by law. Notwithstanding the foregoing, Third Party Data may at times be viewed or accessed by Traverse Systems for the purpose of resolving a problem, support issue, or for investigating a suspected violation of any agreement governing the Service, or as may be required by law.
2. What Personal Information About Customers Does Traverse Systems Collect?
We collect the following types of information from our customers:
a. Information You Provide to Us. Traverse Systems collects identifying information when you use the Service or visit the Site. For example, we require customers who register to use the Service to give us the following personal information: their name, company name, address, phone number, and e-mail address, and financial qualification and billing information, such as billing name and address, credit card number, and the identity of users within the organization that will be using the Service. When you initially express interest in obtaining additional information about the Service, or when you register for the Service, we may also ask for additional types of personal information, such as title, department name, fax number, or additional company information, such as annual revenues or marketing spend. We may also request demographic information and unique identifiers in order to provide you with a more personalized experience or verify your passwords.
All financial and billing information that we collect from you is used for the purpose of billing you for the Service. Such billing information is not used by Traverse Systems for marketing or promotional purposes. Traverse Systems may use a third-party intermediary to manage the credit card and billing processing. This intermediary is solely a link in the distribution chain, and is not permitted to store, retain, or use the information provided, except for the sole purpose of credit card and billing processing. If you are a registered user of Traverse Systems’ subscription-based Service, please note that some information about you may remain in our records after the end of your trial or subscription.
b. Automatic Information: We receive and store certain types of information whenever you interact with us via the Site. Traverse Systems automatically receives and records certain “traffic data” on our server logs, including your IP address, Traverse Systems cookie information, the page you requested, and your communications and interactions with Traverse Systems and other Site registrants. Traverse Systems uses this traffic data to help diagnose problems with its servers, analyze trends, and administer the Service.
We automatically collect usage information, such as the numbers and frequency of visitors to our Site and use of components of our Service. We may use this information to provide research, advice and information, including, without limitation, for benchmarking purposes (e.g. we may publish an industry white paper that uses data collected through the use of our Service). This data is only used in the aggregate. This type of collective data also enables us to figure out how often customers use parts of the Service so we can make the Service appealing to as many customers as possible. In addition, we may provide statistical information to our business partners about how our customers, collectively, use our Site and Service. We may share this type of statistical data so that our business partners also understand how often people use various areas of our Site and our Service, so that they, too, may provide you with an optimal experience.
We also collect and use information for internal purposes. For example, if you are a registered user of Traverse Systems’ subscription-based Service, we may keep records in your account history of your comments or complaints about the Service, and any reported violation of any Service agreement that you or someone on your account may have committed.
c. E-mail Communications. We may receive a confirmation when you open an e-mail from Traverse Systems if your computer supports this type of program, in order to help us make e-mails more interesting and helpful. We may also send out emails with information regarding Traverse Systems or our business partners including promotions and events. Customers can opt out of being contacted by us by sending an email to firstname.lastname@example.org.
d. Information From Other Sources. For purposes such as improving personalization of our Service, we may receive information about you from other sources and add it to our account information.
3. What about Cookies?
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages in our Site are visited and by how many people. Traverse Systems employs cookies in order for its server to recognize a return visitor as a unique user. The cookies placed by the Traverse Systems server are readable only by Traverse Systems, and cookies cannot access, read, or modify any other data on a computer.
4. Will Traverse Systems Share Any of the Information it Receives?
Information about our customers is an integral part of our business. We do not rent, sell, or otherwise distribute your personal or business information to anyone. We share your information only with entities that control, are controlled by, or under common control with Traverse Systems, and as described below:
a. Affiliated Business We Do Not Control We are affiliated or partnered with (in a business sense, not a legal sense) a variety of businesses and work closely with them. In certain situations, these businesses operate within the Service or through the Site. In other situations, Traverse Systems markets or sells products or services jointly with affiliated businesses. We will plainly disclose any program where we intend to share your information with an affiliated business and give you the opportunity to decline to supply customer information or to opt out of such sharing.
b. Agents We employ other companies and people to perform tasks on our behalf and may need to share your information with them to provide products or services to you. Examples may include removing repetitive information from customer lists, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service. We may also provide your information to agents who will use it to verify aggregate usage data that we provide to our business partners. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to Traverse Systems’ privacy and customer data handling policies.
c. Promotional Offers We may send offers to certain customers on behalf of other businesses with whom we have a relationship. However, when we do so, we do not give the other business your name and address. If you are a registered user of the Traverse Systems subscription-based Service and do not wish to receive these offers, please send an email to email@example.com.
d. Business Transfers. In some cases, we may choose to buy or sell assets or businesses. In these types of transactions, customer information is typically one of the business assets that are transferred. Moreover, if Traverse Systems, or substantially all of its assets, were acquired, customer information would be one of the assets that are transferred.
e. Protection of Traverse Systems and Others Protection of Traverse Systems and Others. We may release information when we believe in good faith that release is necessary to: (i) comply with the law; (ii) enforce or apply our conditions of use and other agreements; or (iii) protect the rights, property, or safety of Traverse Systems, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
f. With Your Consent Except as set forth above, you will be notified when your personal information may be shared with third parties.
5. Is My Information Secure?
All customer information collected and stored by Traverse Systems is maintained in a corporate data center and/or otherwise subject to reasonable and customary information security protections. Only employees or contractors who need customer information to perform a specific job (for example, a customer service representative) are granted access to it. All of our employees and contractors are kept up to date on our privacy and security practices. However, the storage and transmission of information via the internet is not completely secure. Although we exercise commercially reasonable measures to protect your personal information, we cannot guarantee the security of your personal information. We are not responsible for circumvention of any privacy settings or security measures contained in the Service.
6. What Legal Procedures Does Traverse Systems Follow with Respect to the Information it Collects?
a. DMCA Copyright Notifications. We do not knowingly permit anyone to post materials on a site where such posting would violate copyright or other applicable law, including the Digital Millennium Copyright Act (“DMCA”) (including 17 USC § 512). If you are a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed by any material on the Site, you may notify us of claimed infringement by sending to us a notice containing the following elements.
- A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
- Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at the Site.
- Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate the material.
- Information reasonably sufficient to permit Traverse Systems to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted.
- A statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.
- A statement that the information in the notification is accurate and, under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
Our designated agent for receipt of such notices is: firstname.lastname@example.org.
b. CAN-SPAM, Telephone Consumer Protection Act and Similar Law. Your use of the Site establishes a business or other applicable relationship with Traverse Systems for purposes of CAN-SPAM, the Telephone Consumer Protection Act, and all other applicable law that addresses unsolicited commercial communications. By accessing, or continuing to access, the Site, you agree that we or our agents may call, e-mail, or otherwise communicate with you regarding promotion of the sale, lease, or exchange of goods, services, real property, or any other thing of value.
c. Misuse of the Site. You may not make any statements on, or provide or post any information to, the Site that is defamatory, threatening, obscene, harassing, or otherwise unlawful, or that, without due authorization, incorporates the proprietary material of another. Any user account can be revoked for misuse as determined by Traverse Systems.
d. Children’s Online Privacy Protection Act (COPPA) Compliance and Related Information. The Children’s Online Privacy Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is Traverse Systems’ policy to refrain from knowingly collecting or maintaining personally identifiable information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personally identifiable information through the Site. If you are under the age of 18 and have already provided personally identifiable information through the Site, please have your parent or guardian contact us immediately using the information below so that we can remove such information from our files.
e. Misappropriation of Personal Information. For the purposes of any applicable law regarding notification of persons whose personal information was, or is reasonably believed to have been, acquired by an unauthorized person, our company policy provides that any required notification may, where permitted by law, be made by the use of e-mail, telephone, fax, mail (including a notice printed in an available area of a bill or statement) or posting a notice on the Site. The specific means used is up to Traverse Systems and we will use our judgment based on the circumstances. Where any notice is to be sent to a specific address or number (such as e-mail address, physical address, telephone number, etc.), we will use the latest available address in our records. You are responsible for ensuring we have an up-to-date active and deliverable email address for you. EXCEPT TO THE EXTENT PROHIBITED BY LAW, YOU AGREE TO THIS MEANS OF NOTIFICATION.
f. European Union General Data Protection Regulation. This Statement is not subject to and expressly excludes the European Union General Data Protection Regulation (“GDPR”) and any other foreign privacy rules. You represent and warrant that you will not transmit any data to us that is subject to the GDPR or any other data protection laws of any other jurisdiction outside the United States. YOU WILL INDEMNIFY US FROM AND AGAINST ANY CLAIMS, DEMANDS, DAMAGES, AND LIABILITIES ARISING OUT OF ANY BREACH OF THIS OBLIGATION.
g. Privacy Impact Assessments. This Statement is not subject to and expressly excludes any obligations to conduct any privacy impact assessments (“PIA”) under any PIA guides or similar rules or regulations of any federal agency or otherwise. You represent and warrant that you will not transmit any data to us that is subject to any PIA requirement. YOU WILL INDEMNIFY US FROM AND AGAINST ANY CLAIMS, DEMANDS, DAMAGES, AND LIABILITIES ARISING OUT OF ANY BREACH OF THIS OBLIGATION.
7. How Can I Correct or Remove Information about Me or My Business?
If you feel that any personal information about you that has been collected and stored by Traverse Systems might be wrong, or you would like for us to remove you from our systems, please notify us at email@example.com so that we may correct or delete the information.
8. What Choices Do I Have?
As stated previously, you can always opt not to disclose information, even though it may be needed to make a purchase or take advantage of certain Traverse Systems features. You are able to add or update certain information as described in the “How Can I Correct or Remove Information about Me or My Business” section above. When you update information, however, we may maintain a copy of the unrevised information in our records.
9. Conditions of Use
If you decide to visit the Traverse Systems Site, your visit and any possible dispute over privacy is subject to this Statement and any other applicable agreement between Traverse Systems and you or your company, including limitations on damages, arbitration of disputes, and application of Texas law.
10. Third Party Sites
The Site or the Service may permit you to link to other websites on the Internet, and other websites may contain links to the Traverse Systems Site. Those other websites are not under Traverse Systems control, and such links do not constitute an endorsement by Traverse Systems of those other websites or the services offered through them. The privacy and security practices of websites linked to or from the Traverse Systems site are not covered by this Privacy Statement, and Traverse Systems is not responsible for the privacy or security practices or the content of such websites.
11. Changes to this Statement
Traverse Systems may amend this Statement from time to time. Use of information we collect now is subject to the Statement in effect at the time such information is used. If we make changes to our Statement, we will notify you by posting the revised notice on our Site or sending you an email so you are always aware of what information we collect, how we use it, and under what circumstances, if any, it is disclosed. You are responsible for maintaining your awareness of any such amendments to this Statement as so posted or noticed.
12. Questions or Concerns
If you have any questions or concerns regarding privacy at Traverse Systems’ Site, please email us at firstname.lastname@example.org.
Revision date: 06/17/2019