Version 1.2 - Updated 8/18/2020
All customers enter into an agreement in order to access and use the Gremlin software-as-a-service offering (”Terms of Service”). The Terms of Service, located at https://www.gremlin.com/terms/, govern the submission, access to and use of any Customer Data (information submitted through the Gremlin service, including emails or names for the purpose of logging into the service and receiving service related notifications). Customer Data may include personally identifiable information. The organization (e.g., your employer) that entered into the Terms of Service (the ”Customer”) controls the particular instance of the Service and any associated Customer Data.
More specifically, when you register with our Services as a user, we will collect your name, email address, and password. We also collect Personal Information from you when you subscribe to our mailing lists (either through our website or otherwise) or respond to a survey (whether sent by us or by one of our partners that provides business related services to us (e.g. SurveyMonkey)). If you make an inquiry through our website, or contact us in any other way, we may keep a copy of your communications with us. For example, if you call us, we may record the phone call for quality and/or reference purposes (e.g. we may record phone interviews with potential candidates applying for positions at Gremlin); if we wish to record our phone call, we will notify you and obtain your permission before doing so.
We may also collect certain technical information by automatic means when you use our Services: this information is typically the information sent to us by your HTTP header and may include IP address, browser type and configurations, and operating system, the website you visited before visiting our website, and usage data resulting from your use of our website (such as hit and conversion rates). Through our software-as-a-service offering, we automatically collect and aggregate data regarding your use of the Services, such as how long an experiment is run and whether the experiment fails or succeeds. We automatically collect certain information on our Services using cookies, web beacons, locally shared objects (sometimes called “flash cookies”), mobile identifiers and similar technologies (”Cookies”).
We have also implemented certain Google Analytics services, which may categorize Cookie information so that we and third-party service providers can better deliver advertisements that are relevant and useful to you on the Services and various websites across the internet.
We may combine the information Ad Partners collect from you with information we collect through our Services. For example, if you authenticate with your Gremlin account via a single sign-on method, such as SAML, we will have access to information that authentication provider sends, such as your email address.
We may also allow Ad Partners to serve advertisements on our behalf across the Internet and in third party applications.
We do not intentionally gather personal information from visitors who are under the age of 13. If you are under the age of 13, you are not permitted to submit any personal information to us or to otherwise use our Services. If we learn that a child under 13 submits personal information to Gremlin, we will delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us using the information in the “Contact Us” section at the bottom of this Policy.
We do not currently respond to ‘do not track’ signals and similar settings or mechanisms. It is critical that we be able to quickly respond to any security or operations issues that may occur within our Services; responding to ‘do not track’ signals would inhibit our ability to do so.
We may use information about you for various purposes, including:
We will only share your information with third parties under the following circumstances:
We do not sell or trade your Personal Information to third parties.
The information about you that we collect, process and/or use through our Services (including your login information) and the data we keep in our third-party business services accounts (e.g. Salesforce) is controlled by Gremlin, Inc. Gremlin and the Services it provides are hosted and provided outside of the European Economic Area (EEA), including in the United States, for the purposes described in this policy. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country. The information that is held by our Ad Partners or other third-party service provider, such as Google Analytics or Salesforce, we are the processor for such data, such data is always hosted by and remains under the control of such Ad Partner or other third-party service provider.
For the data that we control, you have the following data protection rights:
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. If you would like to contact us regarding any of the above, please contact us at the contact information provided in the “Contact Us” section below. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Gremlin, Inc. participates in and has certified its compliance with both the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union (EU), European Economic Area (EEA), and Switzerland to the United States, respectively. Gremlin, Inc. is committed to subjecting all Personal Information received from the EU member countries, EEA and Switzerland, in reliance on the Privacy Shield Frameworks, to the Framework’s applicable Principles. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield List.
Subjects with inquiries or complaints relating to our Privacy Shield certifications should first contact Gremlin Inc. by emailing email@example.com. If we are unable to resolve your complaint or dispute, you may refer your complaint to our designated independent dispute resolution mechanism, the International Centre for Dispute Resolution (“ICDR”), operated by the American Arbitration Association (“AAA”). For more information and to file a complaint, you may contact the International Centre for Dispute Resolution by phone at +1.212.484.4181, or by visiting the website https://go.adr.org/privacyshield.html. Under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Under the Privacy Shield Framework, Gremlin, Inc. is subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us at firstname.lastname@example.org. EU HR Data Independent Recourse: https://edpb.europa.eu/about-edpb/board/members_en
Gremlin, Inc. remains accountable for personal information that it receives under the Privacy Shield and any subsequent transfers to a third party as described in the Privacy Shield Principles.
Occasionally, at our discretion, we may include links to third parties on our websites or in email correspondence. If you access other websites using the links provided, the operators of these websites may collect information from you that will be used by them in accordance with their privacy policies. These third party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
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