Who we are
Our website address is: gastonmedia.io
Information you provide to us. When registering for or using the GastonMedia Services we collect personal information provided by you. For example, when you create a GastonMedia Sign account, you may provide us with your name, account name, alias, employment-related information (to the extent you are using an employer’s business account), email address and a password, your phone number, your address and an electronic image of your avatar. (“Account information”).
You may provide us with personal information about other individuals when you use our Service, such as when you send or receive a request/workflow transaction, share information about such transactions, or ask others to electronically share documents (“Your content”). You may also provide us with access to your contacts (“Contacts”) to make it easy for you to do things like share and collaborate with others, send messages, and invite others to use the Services. Contacts’ information may include personal information such as a real name, alias or email address.
Information that we collect automatically. We collect information related to how you use the Services, including actions you take in your account (like sharing, editing, viewing, creating content) (“Usage information”). We use this information to provide, improve, and promote our Services, and to protect users of the GastonMedia Services. We also collect information from and about the devices you use to access the GastonMedia Services. This includes things like IP addresses, unique personal identifiers or online identifiers, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices (“Device information”). Your devices (depending on their settings) may also transmit location information to the GastonMedia Services. For example, we use device information to detect abuse and identify and troubleshoot bugs.
Information that we collect from third parties. We may share and/or collect additional information about you from third parties primarily to assist us in understanding how we can maintain and improve the services we offer to better serve you. We collect information like your purchasing or consuming history or tendencies, including products or services purchased, obtained or considered (“Commercial information”). For example:
· Analytics: We use services like Google Analytics and Heap, which use cookies and other tracking technologies to gather usage data that allows us to improve our products and services.
· Advertising: We use certain Google advertising features including Google Analytics Demographics and Interest Reporting and Remarketing. Third-party vendors, including Google, may show ads for the GastonMedia Services on sites across the Internet. We and third-party vendors, including Google, use first-party cookies and third-party cookies together to inform, optimize, and serve ads based on someone’s past visits to our website.
· We partner with third parties to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies to provide you advertising based on your browsing activities and interests. If you wish to opt out of interest-based advertising, click www.aboutads.info/choices [or if located in the European Union click www.youronlechoices.eu]. Please note you may continue to receive generic ads.
· Mobile: We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the application.
Information we collect and process on behalf of you. The use of information collected through the GastonMedia Services shall be limited to the purpose for which you have engaged GastonMedia. When you use the GastonMedia Services, we process and store certain information on your behalf as a data processor. For example, when a customer uploads documents for review or sharing, we act as a data processor and process information on the customer’s behalf and in accordance with the customer’s instructions. In this situation, the customer is the data controller and is responsible for most aspects of the processing of the information.
If you are Customer that is based in the United States, its territories and possessions, Canada or Mexico, GastonMedia, LLC. acts as your service provider. For all other Customers, GastonMedia, LLC acts as a processor of your data.
GastonMedia acknowledges that you have the right to access your personal information. GastonMedia has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete data should direct their questions to GastonMedia’s customers (the data controller). If requested to remove data we will respond within a reasonable timeframe. If you have any questions or concerns about how information is processed in these cases, including how to exercise your rights as a data subject, we recommend contacting the relevant customer.
Cookies and other technologies. We use technologies like cookies and pixel tags to provide, improve, protect, and promote the GastonMedia Services. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with the GastonMedia Services, and improving them based on that information. We may also use third-party service providers that set cookies and similar technologies to promote the GastonMedia Services.
GastonMedia and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the GastonMedia Services. To manage Flash cookies, please click here (www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html).
We do not recognize or respond to browser-initiated Do Not Track signals.
HOW WE USE YOUR INFORMATION
We may use the information we collect through our products for a number of reasons, including to:
· provide, improve, protect, and promote our products and services;
· set your account(s);
· send you records of your use of the service, including for purchases or other events;
· understand how you use our products and customize your experience;
· send you marketing communications (in accordance with your subscription preferences);
· record details about your electronic requests, workflows and other transactions (such as when they were opened, shared, and when/where this took place);
· provide customer support;
· respond to your inquiries and requests;
· fix issues or problems with our products and services;
· prevent abuse of the products and services we offer; and
· carry out other lawful purposes about which we will notify our users and customers.
We may also combine the information we collect (or that is otherwise provided to us) through aggregation and other means to limit the identification of any particular individual to help with our business goals (such as research and marketing).
We give users the option to use some of the GastonMedia Services free of charge. These free GastonMedia Services are made possible by the fact that some users upgrade to one of our paid GastonMedia Services. If you register for the GastonMedia Services, we may, from time to time, send you information about upgrades. Users who receive these marketing materials can opt out at any time. If you don’t want to receive a particular type of marketing material from us, click the ‘unsubscribe’ link in the corresponding emails, or contact us using the contact details provided below (if using the contact details please provide your complete name, e-mail address, and any other relevant information that may be required to respond to your request). Please note that such marketing opt-out does not impact any transactional or operational notices that we may need to send you.
We sometimes contact people who don’t have a GastonMedia account. For recipients in the EU, we or a third party will obtain consent before reaching out. If you receive an email and no longer wish to be contacted by GastonMedia, you can unsubscribe and remove yourself from our contact list via the message itself.
Bases for processing your information. We collect and use the personal data described above in order to provide you with the GastonMedia Services in a reliable and secure manner. We also collect and use personal data for our legitimate business needs. To the extent we process your personal data for other purposes, we ask for your consent in advance or require that our partners obtain such consent.
If you have questions about, or need further information concerning, the lawful bases for processing your data, please contact us using the contact details provided under the ‘How to contact us’ heading below.
HOW WE MAY SHARE YOUR INFORMATION
We do not sell your information. We may share your personally identifiable information as described below:
· Vendors and other third-party service providers: We may share your information with third parties that we use for the business purposes of helping us to provide and support the GastonMedia Services. These parties provide services such as authentication, billing and collections, customer support, or data storage. We enter into legally binding agreements with these third-party service providers that protect your personal information and forbids such providers from using your information for their own purposes. These third parties will access your information to perform tasks on our behalf, and we’ll remain responsible for their handling of your information per our instructions.
· GastonMedia has collected and disclosed the following categories of personal information, as described above, to vendors and third-party service providers in the preceding 12 months:
· Account Information: includes your identifying information, which could be your real name, alias, unique personal identifier or online identifier, and it could include other personal information like your postal address, Internet Protocol address, email address, account name or similar identifiers.
· Commercial information: such as your purchasing or consuming history or tendencies, including products or services purchased, obtained or considered.
· Your content: what you and your users decide to input into the fields in the GastonMedia and GastonMedia forms that you create and/or fill out.
· Contacts: includes identifying information about contacts that you’ve chosen to give us access to, like a real name, alias or email address.
· Usage information: includes information relating to your use of the GastonMedia Services. Because GastonMedia provides online services, this may include internet or other electronic network activity information, such as information regarding your interaction with websites, applications, or advertisements.
· Device information: information about the particular devices you use to access the GastonMedia Services, which may include Usage information or device-specific information, such as an online identifier or Internet Protocol address, or geolocation data.
· Cookies and other technologies: technologies like cookies and pixel tags. These technologies can lead to the collection of online identifiers, Internet Protocol address, or other similar identifiers, as well as Usage information.
· Other GastonMedia Companies: the GastonMedia Services share infrastructure, systems, and technology with other services and companies owned or operated by GastonMedia, Inc. (“GastonMedia Companies”) to provide, improve, protect, and promote services provided by GastonMedia Companies. We process your information across the GastonMedia Companies for these purposes, as permitted by applicable law and in accordance with their terms and policies.
· Compliance with Law, Safety, Security, and Business Transactions: We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of the GastonMedia Services or our users; (d) protect GastonMedia’s rights, property, safety, or interest; or (e) perform a task carried out in the public interest.
· To other persons with your consent (e.g. fulfilling your requests).
· Other users: the GastonMedia Services display information like your name, profile picture, device, email address, and usage information to other users you collaborate or choose to share with. When you register your GastonMedia account with an email address on a domain owned by your employer or organization, we may help collaborators and administrators find you and your team by making some of your basic information – like your name, team name, profile picture, and email address – visible to other users on the same domain. This helps you sync up with teams you can join, and helps other users share files and documents with you.
· If you choose to opt-in to updates or marketing about the GastonMedia Services, we will email you with updates and offers, or inform you about other services and features.
RETENTION OF INFORMATION
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other lawful purposes.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW WE PROTECT YOUR INFORMATION
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at privacy@gastonmedia.io
YOUR CHOICES ABOUT YOUR INFORMATION
Upon your written request (for which email is sufficient), GastonMedia will provide you with information about whether we hold any of your personal information, the business or commercial purpose for collecting it, the types of sources we got it from and types of third parties we’ve shared it with. You may submit a data access request, request that your personal data be deleted, or object to the processing of your personal information by logging into your account, or by contacting us using the contact details below. We will respond to your request within a reasonable timeframe. We will not discriminate against you for exercising any of these rights.
CHILDREN’S PRIVACY
The GastonMedia Services are not intended for use by or directed to minors. We do not knowingly collect or ask for information from minors. We do not knowingly allow minors to use the GastonMedia Services. Any person who provides their information to GastonMedia through the account login page for new customers, signup page, or any other part of the GastonMedia Services represents to GastonMedia that they are of legal age (18 years of age or older or otherwise of legal age in your resident jurisdiction) and competent to agree to these Terms. We will delete any information we discover is collected from a minor without permission from their parent(s) or legal guardian(s). Please contact us using the contact details below if you believe you may have provided GastonMedia with a minor’s information without permission from their parent(s) or legal guardian(s).
WHERE WE MAY STORE, PROCESS, OR TRANSMIT YOUR INFORMATION
General. By using the GastonMedia Services you acknowledge and agree that: (i) your information will be processed as described in this Privacy Policy; and (ii) you consent to have your information transferred to us and our facilities in the United States or elsewhere, including those of third parties as described in this Privacy Policy.
Around the world. To provide you with the GastonMedia Services, we may store, process, and transmit data in the United States and locations around the world—including those outside your country. Data may also be stored locally on the devices you use to access the GastonMedia Services.
Data Transfers. When transferring data from the European Union, the European Economic Area, the United Kingdom, and Switzerland, GastonMedia relies upon a variety of legal mechanisms, such as contracts with our customers and affiliates, Standard Contractual Clauses, and the European Commission’s adequacy decisions about certain countries, as applicable.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield. GastonMedia complies with 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 data transferred from the European Union, the European Economic Area, the United Kingdom, and Switzerland to the United States, although GastonMedia does not rely on the EU-U.S. Privacy Shield or Swiss-U.S. Privacy Shield Frameworks as a legal basis for transfers of personal data. GastonMedia has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such data. You can also learn more about Privacy Shield at www.privacyshield.gov.
GastonMedia is subject to oversight by the U.S. Federal Trade Commission. JAMS is the US-based independent organization responsible for reviewing and resolving complaints about our Privacy Shield compliance—free of charge to you. We ask that you first submit any such complaints directly to us via privacy@gastonmedia.io . If you aren’t satisfied with our response, please contact JAMS at www.jamsadr.com/eu-us-privacy-shield. In the event your concern still isn’t addressed by JAMS, you may be entitled to a binding arbitration under Privacy Shield and its principles.
Our EEA Representative. GastonMedia LLC has been appointed as GastonMedia’s representative in the EEA for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. GastonMedia LLC can be contacted in matters related to the processing of Personal Data. To make such an inquiry, please contact GastonMedia LLC by emailing privacy@gastonmedia.io . If they can’t answer your question, you have a right to raise questions or complaints with your local Data Protection Authority at any time.
CHANGES TO THIS POLICY
If we change our privacy policies and procedures materially, we will post those changes to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner we will update the ‘effective date’ at the top of this page, and we may also notify you of the change via email or other prominent notice posted on this site or the GastonMedia Services.
HOW TO CONTACT US
For questions or concerns regarding the collection, use, or disclosure of your information, you can contact us by sending an email to privacy@gastonmedia.io