Findem, Inc. (“Findem,” “we,” “us,” “our,” or the “Company”) is committed to protecting the privacy of individuals who visit the Company’s Web Sites (“Visitors”), individuals who register to use the Services as defined below (“Customers”), and individuals who register to receive informational documentation or demos, or to attend the Company’s corporate events (“Attendees”).
As detailed below, this privacy policy (“Policy” or “Privacy Statement”) applies to Findem’s Web Sites, and all services provided by Findem. This Policy explains how the personal information of Visitors, Customers, and Attendees (collectively, “you,” or “your”), if collected, is used, protected, and, in very limited circumstances, disclosed by Findem. The use of information collected through our service shall be limited to the purpose of providing the Sites and/or Services.
This Privacy Statement also describes Findem’s privacy practices in relation to the use of the Company’s Web Sites and the related applications, services, and programs offered by Findem (collectively, the “Services”), as well as individuals’ choices regarding use, access and correction of personal information.
This Privacy Statement covers the information practices, including how the Company collects, uses, shares and secures the personal information you provide, of Web Sites that link to this Privacy Statement (collectively referred to as “Sites”, “Findem’s Websites” or “the Company’s Web Sites”). Currently, the Company’s Web Sites consist of the following:
Findem [https://www.findem.ai/] and all of its subdomains.
We may change this Policy from time to time. If we make any changes to this Policy, we will change the last updated date at the bottom of this policy. Findem will provide notification of any material changes to this Privacy Statement through the Company’s Web Sites at least thirty (30) business days prior to the change taking effect. We encourage you to check this Policy whenever you use our Site and services to understand how your personal information is used.
We collect two general types of information, namely personal information and aggregate data. As used in this Policy, the term “personal information” means information that specifically identifies an individual (such as a name and email address), and demographic and other information when directly linked to information that can identify an individual. Our definition of personal information does not include “aggregate” data.
Aggregate data is information we collect about a group or category of services or users from which individual user identities have been removed. In other words, no personal information is included in aggregate data. Aggregate data helps us understand trends in our users’ needs so that we can better consider new features or otherwise tailor our services. This Policy in no way restricts or limits our collection and use of aggregate data, and we may share aggregate data about our users with third parties for various purposes, including to help us better understand our customer needs and improve our services and for advertising and marketing purposes.
Personal information is information we collect from you in various ways when you use our Site and services. Examples include the following:
Required Contact Information, Billing Information, Registration and Profile Information, Submissions and Customer Service Information, Optional Information, Applicant Information, and any other information you submit to Findem to or through the Services are referred to collectively as “Data.”
As you navigate the Company’s Web Sites, Findem may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web Sites (such as the Web pages viewed and the links clicked). A more detailed description of Web Site Navigational Information is provided below.
Findem uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web Sites (“Web Site Navigational Information”). As described more fully below, we and our partners use these cookies or similar technologies to analyze trends, administer Web Sites and Services, track users’ movements around our Web Sites and Services, serve targeted advertisements and gather demographic information about our user base as a whole. This Section describes the types of Web Site Navigational Information used on the Company’s Web Sites and Services, and how this information may be used. Among other things, the use of cookies and Web beacons enables us to improve our Site and emails by seeing which areas and features are most popular, to count the number of computers accessing our Site, to personalize and improve your experience, to record your preferences, and to allow you to visit our Site without re-entering your member ID and/or password.
A cookie is a small amount of data which is sent to your browser from a Site’s computers and stored on your computer’s hard drive. Most browsers automatically accept cookies as the default setting. You can modify your browser setting to reject our cookies or to prompt you before accepting a cookie by editing your browser options. However, if a browser is set to not accept cookies or if a user rejects a cookie, some portions of the Site and services may not function properly. For example, you may not be able to sign in and access certain Web page features or services. Standing alone, cookies do not personally identify you; they merely recognize your Web browser. Unless you choose to identify yourself to Findem, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Contact Me” or a “Free Trial” Web form) or have previously identified yourself to Findem, you remain anonymous to the Company.
Findem uses cookies that are both session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer or device when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. 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 our Web Sites or Services. The following sets out how Findem uses different categories of cookies and your options for managing cookies’ settings:
The use of cookies by our partners, affiliates, tracking utility company, and service providers are not covered by our Privacy Statement. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, and service providers use session ID cookies to make it easier for you to navigate our site.
A Web beacon is an electronic image, also called a “gif,” that may be used on our Web pages to deliver cookies, count visits and compile statistics on usage and campaign effectiveness or in our emails to tell if an email has been opened and acted upon. For example, Findem may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web Sites. Findem uses Web beacons to operate and improve the Company’s Web Sites, Services and email communications.
As is true of most Web Sites, we gather certain information automatically to analyze trends in the aggregate and administer our Web Sites and Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use the Company’s Websites and Services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our Website. This information is used to analyze overall trends, to help us improve our Websites and Services, to track and aggregate non-personal information, and to provide the Websites and Services. For example, Findem uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web Sites. Findem also collects IP addresses from Customers when they log into the Services as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features.
The Company’s Web Sites may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect your IP address and which page you are visiting on the Company’s Web site and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on the Company’s Web site to a profile page of yours that is provided by a third party social media network in order to share with others within your network. Social Media Features are either hosted by a third party or hosted directly on the Company’s Web site. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features. Findem also allows you to log in to certain of our Web Sites and Services using sign-in services through the SAML 2.0 protocol. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form.
Currently, various browsers — including Internet Explorer, Firefox, and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web Sites’ visited by the user about the user’s browser DNT preference setting. Findem does not currently commit to responding to browsers’ DNT signals with respect to the Company’s Web Sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Findem takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
In general, we use your personal information to process your requests or transactions, to provide you with information or services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to facilitate your use of, and our administration and operation of, the Site and services and to otherwise serve you and our users. For example, we may use your personal information:
Findem may store and process personal information in the United States and other countries.
Findem may also receive information about Customers and Attendees from other sources, including third parties from whom we have purchased data, and combine this information with Data we already have about you. This helps us to update, expand and analyze our records, and identify new customers.
Findem uses Web Site Navigational Information to operate and improve the Company’s Web Sites. The Company may also use Web Site Navigational Information alone or in combination with Data about Findem Customers and Data about Findem Attendees to provide personalized information about the Company.
Findem partners with third parties to display advertising on our Web Sites and Services or to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies provide you advertising based upon your browsing activities and interests.
Findem reserves the right to share aggregated demographic information about our customers, sales, and traffic to our partners and advertisers. We will not give, sell, rent, share, or trade any of your personal information or any data that you store using our services to any third party except as outlined in this Policy or with your consent. We may disclose information to a third party to
Per the requirements of the EU-U.S. Privacy Shield Framework, Findem may be liable in cases of onward transfer to third parties not covered by the above exceptions.
Findem may share Data about Findem Visitors, Customers and Attendees with the Company’s contracted service providers so that these service providers can provide services on our behalf. These service providers are authorized to use your personal information only as necessary to provide the requested services to us. Without limiting the foregoing, Findem may also share Data about Findem Visitors, Customers and Attendees with the Company’s service providers to ensure the quality of information provided, and with third–party social networking and media Web Sites, for marketing and advertising on those Web Sites. Unless described in this Privacy Statement, Findem does not share, sell, rent, or trade any information with third parties for their promotional purposes.
From time to time, Findem may partner with other companies to jointly offer products, services, or programs (such as webinars or downloadable content) such as our Workshop partners. If you purchase, specifically express interest in, or register for a jointly–offered product, service, or program from or through Findem, the Company may share Data about Findem Customers collected in connection with your purchase or expression of interest with our partner(s). Findem does not control our business partners’ use of the Data about Findem Customers we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.
Findem does not share Data about Findem Attendees with business partners unless: (1) you specifically opt in to such sharing via an event registration form; or (2) you attend a Company event and allow Findem or any of its business partners to scan your attendee badge. If you do not wish for your information to be shared in this manner, you may choose not to opt in via event registration forms and elect not to have your badge scanned at Company events. If you choose to share your information with business partners in the manners described above, your information will be subject to the business partners’ respective privacy statements.
The above Sections regarding Cookies, Web Beacons, Log Files, IP Addresses, URLs and Other Data specifically addresses the information we or third parties collect through cookies and web beacons, and how you can control cookies through your Web browsers. We may also disclose your personal information to any third party with your prior consent.
Findem reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.
Findem Campaigns and Personally Identifiable Information
By default Findem Customers will not provide or receive any personally identifiable information via the Findem platform. We do not collect or share sensitive information such as browser history, health or financial information, or any other information about a person in a family or household capacity.
If Findem Customers choose to use the campaign feature on Findem, we may provide individuals’ email contact information via the platform, surfaced through Findem partnerships with third-party integrations, which can be used in outreach to potential candidates.
As part of this feature, Findem has the proper privacy controls in place — any individual can opt out of interactions with any company through the Findem platform and enforce their privacy settings. For example, if an individual has been contacted by a Findem Customer utilizing the Findem platform as part of an outreach campaign, the individual has the option to opt-out via an unsubscribe link in the outreach (ie. email). This unsubscribe is enforced for the whole company domain attempting to send correspondence to an individual.
Findem offers Visitors, Customers, and Attendees who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may unsubscribe by contacting us using the information in the “Contacting Us” section below.
Findem may retain your information for a period of time consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account to use our Web Sites or Services and for a reasonable period of time afterward. We also may retain your information during the period of time needed for Findem to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
If your personal information changes, or if you no longer desire our service, you may correct, update or delete it on our Site or deactivate your account by emailing our Customer Support at privacy@findem.ai or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access within 30 days. If you are an employee of a Findem customer, you may need to contact your company’s system administrator for assistance in correcting or updating your information.
Findem may send you communications or data regarding our Site and services, including but not limited to (i) notices about your use of our Site and services, including any notices concerning violations of use, (ii) updates, and (iii) promotional information and materials regarding our products and services. You may opt-out of receiving promotional emails from Findem by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing privacy@findem.ai with your specific request. Opt-out requests will not apply to transactional service messages, such as security alerts and notices about your current account and services.
Our Site includes links to other web sites whose privacy practices may differ from those of Findem. If you submit personal information to any of those web sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit.
Findem may provide bulletin boards, blogs, or chat rooms on the Company’s Web Sites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Findem is not responsible for the personal information you choose to submit in these forums.
Findem posts a list of Customers and testimonials on the Company’s Web Sites that contain information such as Customer names and titles. Findem obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.
We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at website-contact@findem.ai.
Our Site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at website-contact@findem.ai. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Our web site includes social media features, such as the Facebook “like” button and widgets. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our web site. As discussed above, your interactions with these features are governed by the privacy policy of the company providing it.
If you have any questions about this Policy, you should first contact us at website-contact@findem.ai.
Findem is also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Per the requirements of the EU-U.S. Privacy Shield, you may invoke binding arbitration in some cases.
Findem’s Customers may electronically submit data or information to the Services for hosting and processing purposes (“Customer Data”). Findem will not review, share, distribute, or reference any such Customer Data except as provided in Findem’s Terms of Service located at Terms, or as may be required by law. In accordance with Findem’s Terms of Service, Findem may access Customer Data only for the purpose of providing the Services or preventing or addressing service or technical problems or as may be required by law. Additional information about the Company’s privacy and security practices with respect to Customer Data is available upon request.
Findem acknowledges that you have the right to access your personal information. If personal information pertaining to you as an individual has been submitted to us by a Findem customer and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with our customer directly. Because Findem personnel have limited ability to access data our customers submit to our Services, if you wish to make your request directly to Findem, please provide the name of the Findem customer who submitted your data to our Services. We will refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe.
Findem uses robust security measures to protect Data about Findem Customers and Data about Findem Attendees. Because the Company uses the Services to maintain Data about Findem Customers and Data about Findem Attendees, this information, which is stored in the Services, is secured in the same manner as all other Data.
Mobile Applications provided by Findem may obtain information from, or access data stored on, Users’ Devices to provide services related to the relevant Mobile Application. For example, a Mobile Application may: access a camera on a User’s Device to enable the User to upload photographs to the Services; access the geographic location of a User’s Device to enable the User to input an address; or access contact information on a User’s Device to enable the User to sync contact information between the information that is stored on the User’s Device and the information that is submitted to the Services; access third party applications on the device (e.g. Google Maps, Adobe Reader, Outlook, etc.) to enable navigation, open files, or send emails. Information obtained to provide Mobile Application services may include information obtained in preparation for anticipated updates to those services. Mobile Applications may transmit information to and from Devices to provide the Mobile Application services.
Mobile Applications may provide Findem with information related to Users’ use of the Mobile Application services, information regarding Users’ computer systems, and information regarding Users’ interaction with Mobile Applications, which Findem may use to provide and improve the Mobile Application services. For example, all actions taken in a Mobile Application may be logged, along with associated information (such as the time of day when each action was taken). Findem may also share anonymous data about these actions with third party providers of analytics services. In addition, if a Customer purchases more than one Service from Findem and its affiliates, a Mobile Application may be designed to interoperate with those Services; for instance, to provide a User with access to information from any or all of those Services or to provide information from a User’s Device to any or all of those Services. Information accessed or obtained by the Mobile Application on a User’s Device may be accessible to the Customer and its organization, depending on the intended functionality of the Mobile Application. Findem may provide updated versions of its Mobile Applications. If your mobile device’s settings permit, those updates will be downloaded and installed automatically on your mobile device. By installing a Findem Mobile Application on your mobile device, you consent to the downloading and updating of that Mobile Application.
In addition to Mobile Applications offered by Findem, the Company may offer platforms for the creation of third-party Mobile Applications, including but not limited to the Findem Platform. Third parties may obtain information from, or access data stored on, Users’ Devices to provide services associated with any third-party Mobile Applications that Users download, install, use, or otherwise interact with over a Findem platform. Findem’s Mobile Applications may also contain links or integrations to other Mobile Applications provided by third parties. Third parties’ use of information collected through third-party Mobile Applications is governed by the privacy statements of such third parties. The Company encourages you to review the privacy statements of third-party providers of Mobile Applications to understand their information practices.
Notices and contractual terms related to a particular Mobile Application may be found in the Findem Terms of Service or relevant terms of service for that application. Findem encourages you to review the Terms of Service or relevant terms of service related to any Mobile Applications you download, install, use, or otherwise interact with to understand that Mobile Application’s information practices. The Mobile Application’s access to information through a User’s Device does not cause that information to be “Customer Data” under Findem’s Terms of Service with the Customer or under this Privacy Statement, except as follows: To the extent that a User uses a Mobile Application to submit electronic data and information to a Customer account on our Services pursuant to the Findem Terms of Service (or a similar agreement that governs the Customer’s subscription(s) to Findem’s Services), that information constitutes “Customer Data” as defined in such agreement, and the provisions of that agreement with respect to privacy and security of such data will apply. Additional information about the Company’s privacy and security practices with respect to Customer Data is available upon request.
If a customer chooses to use certain Findem services that would require access to the email accounts in order to function, then the following data privacy policies apply. We reserve the right to delete the information stored in our service for inactive/unused accounts. Findem is not liable for actors adding emails violating corporate policy.
Access to email account is needed for sending emails, processing replies, and deleting messages, plus transferring response message content and attachments to the Findem platform.
The data is stored in the Findem platform encrypted at the storage layer, and is only accessible by the platform. The access to the storage server is limited to select administrative staff for maintenance purposes. The storage servers are located in the United States.
The email data is accessible by the customer who had provided the email authorization, and the select team members he/she authorizes to share. App’s use of information received, and App’s transfer of information to any other app, from Google APIs will adhere to the Google API Services User Data Policy including the Limited Use requirements.
The email data is used only for messaging on behalf of the consenting user, and we do not share/modify or use the messages for any purposes other than providing the service to the customer.
This Privacy Statement shall apply even if Findem transfers Data about Findem Customers or Data about Findem Attendees to other countries.
Findem complies with the EU General Data Privacy Regulations (“GDPR”) and complies the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and/or Switzerland to the United States. Findem has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy 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 https://www.privacyshield.gov/
Findem generally operates as a “Processor” of Data under the GDPR, but, depending on the specific circumstances, Findem may occasionally operate as a “Controller” of Data. With respect to Findem’s relationship with its Customers, Findem is a “Processor” of Data and the Customer is the “Controller” of the Data. The Company primarily stores Data about Findem Customers and Data about Findem Attendees in the United States. However, for certain Findem applications, Data may be stored outside of the United States. To facilitate Findem’s global operations, the Company may transfer and access such information from around the world, including from other countries in which the Company has operations. All such transfers and access of such information shall comply with the GDPR and all other applicable data protection and security standards.In compliance with the Privacy Shield Principles, Findem commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Statement should first contact Findem at: website-contact@findem.ai
Findem has further committed to cooperate with EU data protection Supervisory Authorities with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the applicable EU Supervisory Authority for more information or to file a complaint.
Any questions about this Policy should be addressed to privacy@findem.ai.
Last updated: September 2021