Appinium, Inc. (“Appinium”) offers software as a service (“SAAS”) to enterprise clients for use on the Salesforce.com, Inc. platform (“Salesforce platform”). Appinium’s SAAS includes a video player application and a learning engagement application designed to help business clients improve performance by use of video and learning either internally with employees or externally with customers.
Appinium is committed to protecting the private information of all persons who utilize Appinium’s SAAS. To that end, Appinium does not collect or store any private information belonging to any end user, i.e., employees or customers of Appinium’s business clients who access and use Appinium’s video player to view videos or who access and use Appinium’s learning engagement application.
General Information about Appinium Users And Visitors:
Appinium does not collect personal or private information that can be used to identify any specific user or visitor to its website.
If a user is utilizing Appinium’s SAAS for storage when the user launches a video and/or learning application on the Salesforce platform using the Appinium SAAS, Appinium’s SAAS passes the user’s object ID, org ID and IP address to the Appinium back-end server hosted in Microsoft Azure (“Azure”). The user ID and the org ID are then used to confirm that the user is authorized to launch the file and then such information is discarded without being stored anywhere by Appinium or its back-end server hosted by Azure. This process allows Appinium to ensure the user is authorized by Appinium’s business client to launch a media file from the Salesforce platform using Appinium’s video player application.
If a user is utilizing Appinium’s SAAS without using any storage through Appinium’s SAAS, then when the user launches a video and/or learning application on the Salesforce platform using the Appinium SAAS, Appinium does not collect and/or pass on the user’s object ID, org ID and IP address to the Appinium back-end server hosted on Azure.
Appinium will process users’ IP addresses in order to extract the geo location (city / country / region) of the user. The IP address is then discarded without being stored anywhere by Appinium or its back-end server hosted by Azure. The geo information is stored in Azure and is then associated with the file being launched.
Appinium uses its best efforts to maintain any information users submit private and use it only for the purposes and in the manner as set forth herein.
By using the Appinium SAAS, the user hereby consents to the collection and use of data as described above in this Privacy Notice.
Privacy Commitment Changes:
If we decide to change our privacy commitment at Appinium, we will post those changes here so that you will always know what information we gather before we do so, how we might use that information, and whether we will disclose it to anyone and also, we will seek the consent of our users before there is any change. If, at any time, you have questions or concerns about Appinium’s privacy commitment, please feel free to call us at the number below and speak to one of our representatives.
Appinium provides a video and learning platform software as a service to help its customers with improved business performance and abides by the Safe Harbor Principles of the United States Department of Commerce.
Appinium respects the individual privacy of its clients (and our clients’ customers), employees, business partners and others who may use Appinium’s products and services. In all cases, Appinium treats personal information in a manner consistent with the laws of the countries in which Appinium does business, but it also aims to uphold the highest applicable ethical standards in all its business activities.
This Privacy Notice sets forth the privacy principles that Appinium follows with respect to the protection and transfers of personal information, whether it is in electronic, paper or verbal format, between the United States and the EU. This statement applies to all personal information Appinium processes (except as otherwise noted herein), including on-line, off-line, and manually processed data. Any employee whom Appinium determines is in violation of this Privacy Notice will be subject to disciplinary process, up to and including termination.
Consistent with its commitment to protect personal privacy, Appinium declares that it adheres to the Safe Harbor Principles embodied in the Safe Harbor Agreement concerning the transfer of personal data from the European Union to the United States of America. The United States Department of Commerce and the European Commission have agreed on the Safe Harbor Principles as they are articulated in a set of data protection principles and frequently asked questions as a means to enable U.S. companies to satisfy EU law requirements for adequate protection of personal information transferred from the EU to the United States. If there is a conflict between the provisions of this Privacy Notice and the Safe Harbor Principles, the Safe Harbor Principles will govern.
Appinium complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Appinium has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Appinium’s certification, please visit http://www.export.gov/safeharbor/.
The following definitions apply to all statements throughout this Privacy Notice.
“Personal information” means any information or set of information that is transferred from the EU to the United States, is recorded in any form, pertains to or is about any individual, and can be linked to or used to identify that individual. Personal information does not include information that is encoded, anonymized, or publicly available information that has not been combined with non-public personal information. Personal information does not include information that pertains to or is about a specific individual, but from which that individual could not reasonably be identified.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. For purposes of this Privacy Notice, Appinium will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The Privacy Principles:
Appinium’s operations and processing of personal information conform to the following Safe Harbor Privacy Principles as stated below under the heading of each principle.
Notice and Choice:
To the extent permitted by the Safe Harbor Agreement, Appinium reserves the right to process personal information in the course of providing professional services to Appinium’s clients without the knowledge of individuals involved. If and when Appinium collects personal information directly from individuals in the EU, Appinium will inform them about the types of personal information it collects from them, the purposes for which Appinium collects and uses it, and the types of non-agent third parties to which Appinium discloses that information. Appinium will also inform those individuals about the choices and means, if any, that Appinium offers to limit the use or disclosure of their information.
Disclosures and Transfers:
Appinium will not disclose an individual’s personal information to third parties, except when one or more of the following conditions is true:
Appinium has the individual’s permission to make the disclosure;
The disclosure is required by law or professional standards;
The disclosure is reasonably related to the sale or disposition of all or part of Appinium’s business;
The information in question is publicly available;
The disclosure is reasonably necessary for the establishment or defense of legal claims; or
The disclosure is to another Appinium entity or to persons or entities providing services on Appinium’s or the individual’s behalf (each a “transferee”), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
is subject to laws providing an adequate level of privacy protection;
has agreed in writing to provide an adequate level of privacy protection; or
subscribes to the Safe Harbor Principles.
Permitted transfers of information, whether to third parties or within Appinium, include the transfer of data from one jurisdiction to another, including transfers to and from the U.S. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated.
To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of its business clients and users, Appinium has put in place and rigorously enforces appropriate physical, electronic, and managerial procedures to safeguard and secure the information that Appinium processes. However, Appinium cannot guarantee the security of information on or transmitted via the Internet.
As described above, Appinium may collect basic information identifying its business clients. Such information is processed only in ways compatible with the purpose for which it was collected or subsequently authorized by the business client. To the extent necessary for such purposes, Appinium takes reasonable steps to make sure that business client information is accurate, complete, current, and otherwise reliable for its intended use.
Access and Correction:
If a business client becomes aware that information Appinium maintains about that client is inaccurate, or if a business client would like to update or review that party’s information, the client may contact Appinium using the contact information below. In every case, Appinium will take reasonable steps to permit business clients to correct, amend, or delete information that is demonstrated to be inaccurate. The party seeking to amend such information will need to provide sufficient identifying information. Appinium may request additional identifying information as a security precaution. In addition, Appinium may limit or deny access to information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, Appinium may charge a reasonable fee, where warranted.
Enforcement and Dispute Resolution:
Appinium utilizes the self-assessment approach to assure its compliance with this Privacy Notice. Appinium periodically verifies that this Privacy Notice is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Safe Harbor Principles. Appinium encourages interested persons to raise any concerns about its implementation of this Privacy Notice using the contact information below. Appinium will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Privacy Notice.
For complaints and disputes that cannot be resolved between Appinium and the complainant, Appinium has agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the Safe Harbor Privacy Principles, as well as to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland. The panel may be contacted at firstname.lastname@example.org and individual EU DPAs may be contacted directly via the information provided at http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm. The contact information for the Swiss FDPIC can be found at: http://www.edoeb.admin.ch/kontakt/index.html?lang=en.
Appinium is also subject to the jurisdiction of the U.S. Federal Trade Commission.
Appinium may change this Privacy Notice from time to time, consistent with the requirements of the Safe Harbor Principles or the United States Department of Commerce. Appinium will post any revised Privacy Notice in its work places, train its employees about such changes and how to comply with them, and will publish any amended Privacy Notice on this Web site or a similar Web site that replaces this Web site.
Information Subject To Other Policies Or Standards:
Appinium is committed to following the Safe Harbor Principles for all personal information within the scope of the Safe Harbor Agreement. Certain information, however, is subject to policies of Appinium that may differ in some respects from the provisions of this Privacy Notice. Information subject to such additional policies includes information obtained from or relating to a business client that is subject to the terms of any privacy notice to or agreement with such business client, any engagement letter or letters with such business client, and applicable laws and professional standards.
Questions or comments regarding Appinium’s Safe Harbor certification and this Privacy Notice should be submitted to Appinium by mail or e-mail as follows:
1 Sansome St., Ste. 3500
San Francisco, CA 94104