Last updated: June 21, 2020
This policy describes: what data we collect and why; how your data is handled; your rights to your data. We promise to never sell your data.
This policy applies to all products built and maintained by Encoro LLC including all encoro leadership tools.
What we collect and why
Our guiding principle is to collect as little as possible. Here’s what that means for you:
Identity & access
When you sign up for encoro, we ask for your name, email address, and the name of your organization. This is to personalize your account, and so we can send you invoices, updates, or other essential information. We give you the option to add a profile picture, but we do not normally look at or access that picture. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without asking your explicit permission first.
When you pay for encoro, we ask for your credit card in order to charge you for service and send you invoices.
Your credit card is passed directly to our payment processor and doesn’t ever go through our servers. We store an identifier to look up your account with our payment processor for payment history, invoicing, and billing support.
Since July 11, 2019 we have used no third-party web analytics software.
Cookies and Do Not Track
We use persistent first-party cookies to remember your login information so encoro is easier for you to use. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, go to: www.allaboutcookies.org.
At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
Information we do not collect
We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.
We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.
When we access or share your information
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
- To provide products or services you’ve requested We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. You can view the list of third-party services we use: encoro processors. Having subprocessors means we are using technology to access your data. No encoro staff look at your data for these purposes.
- To help you troubleshoot a software bug, with your permission. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.
- To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.
- When required under applicable law. If the appropriate law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made.
Location of site and data
Our products and other web properties are operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.
Your rights with respect to your information
Encoro applies the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. Encoro recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
- Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
- Right to Correction. You have the right to request correction of your personal information.
- Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using encoro because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
- Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
- Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data).
- Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
- Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
- Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
- Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our product, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and directly updating your account information.
If you have questions about exercising these rights or need assistance, please contact us at [email protected] or at encoro, LLC. 24 Mill Street, Easthampton MA 01027 USA. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.
If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.
How we secure your data
All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest.
When you delete data in your product accounts
We delete your data after an account is cancelled. In this case, there is no period of data being kept in an accessible trash can so your data are purged within 60 days. This applies both for cases when an account owner directly cancels and for auto-cancelled accounts.
Changes & questions
We may update this policy as needed to comply with relevant regulations and reflect any new practices.