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Privacy Statement

EFFECTIVE: July 30, 2023

Welcome to our website. This Privacy Statement describes the types of information that Laudio Inc. (“we” or “us”) collects from and about visitors and users (“you”) to any of our web properties, including those you may access through your employer (each a “Site” and collectively the “Sites”). Our public Site, www.laudio.com, provides information about our company and our software, mobile applications and related services; our other Sites provide dedicated client access to our software, platform and related services ( the “Services”).

Your privacy is important to us. This Privacy Statement sets forth our policy with respect to the collection, use and disclosure of personal information and other information that is collected from you on any Site. By using the Sites or Services, you agree to the data collection, use, disclosure and storage practices described in this Privacy Statement. We collect information about you in a range of forms, including personal information, when you choose to provide it to us. Personal information (or personal data) means information about an individual from which that person can be identified. It does not include personal information where the identity has been removed (anonymous personal information). This may include when you contact us with inquiries or otherwise contact us. Where we provide the Services under a contract with a company (for example your employer), that company controls the information collected and used with the Services.

When you interact with us through the Sites or Services, we may collect information from you, as further described below.

Authorized User Notice

If you access the Services through a Site provided by your employer, you are considered an Authorized User under your employer’s contract with us. Your employer decides how the information you provide is collected and used, including what is shared with us for our use.

Before using our Sites or Services, please read and familiarize yourself with your employer’s privacy and other policies and procedures. If you have questions about the collection and use of information on the Sites or Services, please contact your employer.

This Privacy Statement is for informational purposes only and describes how we generally collect and use information. However, how we collect and use information from you as an Authorized User depends on the Services that we provide to your employer.

Laudio may collect personal health information (PHI) or other sensitive information about you in conjunction with services provided to our customers. Laudio has taken steps to comply with the Health Insurance Portability and Accountability Act (“HIPAA”) regulations, and will enter into Business Associate Agreements (“BAAs”) with customers that might share such data.

Information You Provide to Us

The information we collect may include your name, address, email address, telephone number, mobile telephone number or geolocation information or any other information you provide while you use our Services such as login or password. If you use a third-party service to link to us or communicate with us (such as a social network or third-party video chat), we may receive certain information about you from the third party based on your registration and privacy settings on those third party services.

Job Applicants

We may collect the following categories of personal information regarding job applicants:

  • Personal and online identifiers (such as first and last name, email address, cellphone number or unique online identifiers);
  • “Sensitive Information”: physical characteristics or description, medical or heath information (such as disability status), veteran status, social security number, driver’s license or state identification number, address, insurance policy number, and bank account number;
  • Characteristics of protected classifications under federal or state (such as race or gender);
  • Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement);
  • Geolocation information;
  • Professional or employment-related information;
  • Education information;
  • Inferences drawn from the above information about your predicted characteristics and preferences; and
  • Other information about you that is linked to the Personal Information above.

This information is collected directly from job applicants themselves or third parties who have a right to disclose this information to us. We use and disclose your personal information to process, evaluate and communicate with you about their application and qualifications for the position applied for, to check your references and to communicate with you about other jobs for which you may be qualified.

Job applicants may also submit requests to us to know what personal information we may have collected about you, correct your personal information or delete your personal information from our systems and records. You can submit these requests to us via email at grc@laudio.com (put “My Personal Information” in the email subject line) or by mail to us at: Laudio Inc., 876 Boylston St. 5th Floor, PMB 236, Boston, MA, 02116

Information Collected from Other Sources

We may obtain information about you from other sources, including social networks that you use to connect with Us. This information may include name, username, demographic information, updated address or contact information, interests, and publicly-observed data, such as from social media and online activity.

Information Obtained from Third Parties

If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us, for example, if you have agreed to share information with one of our partners, we may add this information to the information we already hold about you.

Information We Automatically Collect

As is true of most websites, we automatically gather information about your computer or mobile device. 

For example, we may automatically collect certain non-personal information from you such as your mobile device identifier or MAC address, browser type, operating system, device model, software version, Internet Protocol (“IP”) address, mobile or ISP carrier information, and the domain name from which you accessed the Sites. We also may collect information about your use of the Sites including the date and time you access the Services, the areas or pages of the Sites that you visit, the amount of time you spend using the Sites, the number of times you return, whether you open forward or click-through emails and other usage data.

Cookies. A cookie is a piece of data stored on your computer’s hard drive that contains information about you and your computer or device. The cookies used on the Sites do not contain any identification that would be useful to another individual or organization. We use cookies, for example, to remember your login information so you do not have to enter a username and password each time you return to the site (should you choose this option). We also use cookies to provide statistical information on website usage and personalize and enhance the online experience. Some of these cookies may be active during the time you are viewing our Sites (“session cookies”). Other cookies may remain on your computer after you have closed your browser or turned off your computer (“persistent cookies”). We do not use tracking cookies on other websites, such as to serve you with targeted online ads.

The following cookies might be deployed on the Sites:

  • Strictly Necessary Cookies: These cookies are strictly necessary to provide the Sites. For example, they are used to authenticate and identify returning users.
  • Performance and Functionality Cookies: These cookies provide statistical information on usage on the Sites, such as web analytics. They also help us to personalize and enhance your online experience.

You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Sites or take full advantage of all of our Services. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. See www.allaboutcookies.org to learn how to disable cookies on your browser or otherwise opt out of cookies. if you set your browser to disable all cookies or opt out, some features of the Sites may not function properly. Note that you cannot opt out of Strictly Necessary Cookies.)

We also use web beacons and pixels on our websites and in emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies to operate and improve our Sites and marketing emails. (You can opt out of receiving marketing emails by emailing us at grc@laudio.com or using the “Unsubscribe” link in the email.)

This Privacy Statement does not cover the use of cookies used by third parties, and we are not responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Sites.

Do Not Track Disclosures. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

Combination of Information

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Sites, as well as information collected offline or from third party sources to help us tailor our communications to you and to improve our Sites and the Services.

Information Use

We may use the information we collect from and about you to:

  • Assess the needs of your business to determine suitable products;
  • Send you requested product or service information;
  • Respond to customer service requests;
  • Send you a newsletter and marketing communications;
  • Respond to your questions and concerns;
  • Improve the content and functionality of our Sites, Services and marketing efforts;
  • Conduct research and analysis;
  • Display content based upon your interests;
  • Comply with applicable laws, including to respond to requests from public and government authorities;
  • Enforce this Privacy Statement;
  • Protect our rights, privacy, safety or property, and/or that of you or others.
  • Develop new programs, products or services
  • Protect the security or integrity of the Sites, the Services and our business; and
  • As described to you at the point of data collection

 

INFORMATION SHARING

We may share the information we collect from and about you:

(1) with affiliated third parties (such as our affiliates or subsidiaries) that we believe may provide promotional materials, and goods and services that may be of interest to you;

(2) to our Service Providers, if the disclosure will enable them to perform a business, professional or technical support function for us;

(3) as necessary if we believe that there has been a violation of this Privacy Statement, our Terms of Use, of our rights or the rights of any third party;

(4) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

(5) to respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, national security or law enforcement, as permitted by law, or otherwise as required by law; and

(6) as described to you at the point of collection.

If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

In the previous 12 months, we have not sold or shared your personal information to third parties as defined in the California Consumer Privacy Act (as amended by the California Privacy Rights Act) or other US state privacy laws.

We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Sites or Services in a manner that is consistent with this Privacy Statement.

If you do not want us to share your personal information as set forth in this Privacy Statement, contact us at grc@laudio.com.

Service Providers

We may contract with third parties to perform functions related to the Services (“Service Providers”). Service Providers will have access to your personal information needed to perform their business functions but may not use or share that personal information for other purposes. These companies are authorized to use your personal information only as necessary to provide these services to us.

If you provide the name of your company, we may use the name of your company (but not other personal information) on a list of current or former customers for promotional purposes.

Your California Privacy Rights

California Civil Code Section §1798.83 permits users of our site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to grc@laudio.com or write us at Laudio Inc., 876 Boylston St. 5th Floor, PMB 236, Boston, MA, 02116

For California residents under the age of 18 and registered users of websites, California law (Business and Professionals Code § 22581) provides that you can request the removal of content or information you posted on the Sites.  Any such request should be sent to us at grc@laudio.com along with a description of the posted content or other information to be removed.  Be advised, however, that applicable law may not permit us to completely or comprehensively remove your deleted content or for other reasons as set forth in this California law. 

The California Online Privacy Protection Act (“CalOPPA”) requires that online privacy notices disclose how a website responds to “Do Not Track” signals. We currently do not honor these signals.

Be advised that in the previously 12 months we did not sell or share your Personal Information to third parties as defined in the California Consumer Privacy Act (as amended by the California Privacy Rights Act). Laudio is not otherwise subject to the California Consumer Privacy Act; however, Laudio will honor Requests to Know, Requests to Correct and Requests to Delete to the extent possible.

Other State Privacy Laws

Residents of other states may provide other privacy rights. Contact us at grc@laudio.com if you have a question about these other state privacy rights and your personal information we may have collected. However, Laudio may not be subject to these other US state privacy laws. 

EEA and UK Residents

For residents of the European Economic Area (EEA) and United Kingdom (UK), we advise that while your personal information will be hosted in the EEA and/or UK, it may be accessed by or transferred to Laudio and its sub-processors located in third countries outside the EEA or UK, including the United States, which third countries may have data protection laws that are different than those in your country and may not be as protective. The United States, in particular, has not received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (GDPR). We have taken steps to comply with the GDPR. 

Our legal basis for collecting and using your personal information is to do so with your consent; where we need the personal information for performance of a contract or requested service, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If we collected your personal information with your consent, you may withdraw your consent at any time.

Our retention of your personal information and any subsequent communications are based on our legitimate interest in providing you with new and potentially relevant materials based on your geography, role, or company. As always, you can elect to opt out from receiving such future communications.

To the extent that we access or transfer personal information from the EEA or UK to a jurisdiction outside the EEA or UK that has not been adduced by the European Commission as providing adequate data protections (such as the United States), we will ensure that such personal information is safeguarded through appropriate contractual terms or other approved mechanisms.

Rights for EEA and UK Residents – If you are a resident of the EEA or UK, you have the right to:

  • Find out if we use your personal information, to access your personal information and receive copies of your personal information.
  • Withdraw any express consent that you have provided to the processing of your personal information at any time without penalty.
  • Access your personal information and have it corrected or amended if it is inaccurate or incomplete.
  • Obtain a transferable copy of some of your personal information which can be transferred to another provider when the personal information was processed based on your consent.
  • If you believe your personal information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your personal information, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
  • Request your personal information be deleted or restricted under certain circumstances. For example, if is using your personal information on the basis of your consent and has no other legal basis to use such, you may request your personal identifiable information be deleted when you withdraw your consent.

To exercise these rights per the GDPR, please contact us via email at grc@laudio.com. We will endeavor to respond to your request within a month but will let you know if additional time is needed. If we obtain your personal information as a data processor, we may forward your request to the relevant data controller to respond directly to you.

If you are not satisfied with our response, or believe we are processing your personal information in violation of the GDPR, you have the right to lodge a complaint with the Supervisory Authority (also known as a Data Protection Authority) or other appropriate governmental authority in your EEA Member State or United Kingdom. A list of Supervisory Authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en or the UK’s Information Committee’s Office’s website is available at: https://ico.org.uk/.

(If you provide your personal information directly to us, we are the data controller. However, if your personal information is provided to us by your employer or other responsible party as part of their use of the Services, we are a data processor and your employer – our customer — is the data controller.)

To withdraw your consent to specific processing, contact us at grc@laudio.com.  However, withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If we ask you to provide personal information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your personal information is required and if not, the consequences of not sharing your personal information with us.

Similarly, if we collect and use your personal information in reliance on our or a third party’s legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.

We endeavor to apply suitable safeguards to protect the privacy and security of your personal information and to use it only consistent with your relationship with us and the practices described in this Privacy Statement.

Children

Protecting children’s privacy is important to us. We do not direct the Sites or Services to, nor do we knowingly collect any personal information from, children under the age of thirteen. If we learn we have collected or received personal information from a child without verification of parental consent, we will delete that information.

Links to Other Websites

This Privacy Statement applies only to the Sites and Services. The Sites or Services may contain links to third-party sites or applications, including social media sites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites or applications. The links to third-party websites from the Sites or Services do not imply that we endorse or have reviewed the third-party websites.

Data Security

The security of your personal information is important to us. We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about You. (A description of our implemented security measures is available at: laudio.com/public-security/.) While we make every effort to help ensure the integrity and security of our network and systems, the transmission of information via the internet is not completely secure. For example,  emails sent to or from the Sites or Services may not be secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Sites or Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or Services.

Data Storage and Retention

For US users, your personal information is stored on servers in the United States. You understand and agree that we may collect, use, disclose, and otherwise process the information you provide as described in this Privacy Statement.   Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States. We will retain your personal information for as long as it is needed to provide you with the Services, or to fulfill any legal or contractual obligations we may have.

As described above, for EU and UK users your personal information will be hosted in the EEA and/or UK,

Access to Your Personal Information

You may also send us an email at grc@laudio.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change or delete information if we believe doing so would violate any law or legal or audit requirement or cause the information to be incorrect.

Changes to Our Privacy Statement

We reserve the right to revise this Privacy Statement at any time. When we do, we will post the changes on the Sites. If we change the Privacy Statement in a material way, we will provide appropriate notice to you. Your continued use of the Sites or Services after any changes or revisions to this Privacy Statement shall indicate your agreement with the terms of such revised Privacy Statement.

Contact Us

Please also feel free to contact us at grc@laudio.com or our address below if you have any questions about our Privacy Statement or the information practices of the Services.

Laudio Inc., 876 Boylston St. 5th Floor, PMB 236, Boston, MA, 02116

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