Effective Date: August 2, 2020 (Ver. 1.0)
Your privacy and trust are a high priority for us. This Policy describes how CREDcube, LLC (referred to below as “CRED3.com”, “CREDcube.com”, “our”, “we”, and “us”) protect, collect, handle and store personal information about you or your company within the framework of our Dashboards, Dashboards collectively “CRED3 Services”. This Policy also provides information about your rights, consent and how to contact us if you have any questions about the handling of your personal information.
The information given below applies to persons who use our Website and CRED3 Services.
Depending on the CRED3 Services chosen by our customers, additional or different privacy notices and statements may be provided. This is to highlight how personal information will be used in a specific context.
Because our services involve the storage and maintenance of personal information and communications, links to third-party websites, software or services may be shown. We are not responsible for the privacy compliance or content of third-party websites, software or services. You should check the third-party websites, software and services for their unique privacy statements and what terms apply to them.
Children’s Privacy: Our services and data storage are geared towards adults, professionals and companies and not aimed at children. The Website and CRED3 Services may not be used by, and are not intended for, any person under 18 years of age without parental guidance and control. CRED3 does not knowingly collect Personal Information from children under 13 years of age (or anyone under 18 years of age who is not under parental guidance and control).
Who We Are:
Our mission is to provide a way for people to measure their emotional health and other performance indicators to enable them to be more productive and successful. To achieve our mission, we make the CRED3 Services and information from you available to others through our Website and CRED3 Services, including limitation, through Content and other Contributions to be Analyzed and Scored and ultimately used by or for Members on their Dashboards. Those Dashboards (including their Content and Contributions) may be distributed a Dashboards and viewed to others (“Advisors” and “Clients”).
Dashboard: A Dashboard is able to change. Information can be added or deleted by Dashboard Owner or the Dashboard Owner’s Representative. Messages and other Content sent to the Dashboard Owner may be added to the Dashboard.
If you are a Contributor:
If you provide Content (including any Personal Information in it) may be included on or in Dashboards and may be transmitted, disclosed or distributed to others. We do not control the Dashboard Owners, their Advisors or Clients of those Dashboards and cannot control or prevent any further transmission, disclosure or distribution of your information in those Dashboards, Messages or other Content. This also applies to any other Contribution you make to a Dashboard.
If you are a Contributor of the Dashboard or other Content, we may analyze your Messages or Content. For example, we may use metrics, voice analytics software, and other techniques to assess emotional health metrics and/or to create CREDibility scores and assessments. If the Contributor CREDibility score does not meet CRED3 minimum scoring thresholds as governed by CRED3, the Dashboard owner will be notified accordingly, and the content will only be available to the Advisor and Client and not for general public use.
If you are a Dashboard Owner, we may analyze your Dashboards to assess CREDibility and/or to create CREDibility scores and assessments.
What Types of Personal Information Do We Collect?
The type of personal information collected depends on the CRED3 Services that are used as well as your interactions with us. You can always choose not to provide us with Personal Information.
If you do not provide certain Personal Information you may not be able to take advantage of the full use of our CRED3 Services.
We typically collect the following types of personal information:
- Your first and last name
- Contact Data (email address, postal address and phone number)
- Account Data (username, passwords and authentication data)
- User content (software, messages, photos, videos, files and communications provided by your in relation to your using of our CRED3 Services).
- Comparisons to other Members
- Payment information (credit card, debit card, security code)
- Device information (IP address, location and provider)
- Browsing History (how you navigate our CRED3 Services and Website)
- We also collect information about your Dashboard’s velocity:
- Analytics including voice analysis
- How many times it has been viewed and by whom.
Sources of Personal Information?
We are both a controller and processor of information. This means for some information we decide how to use Personal Information in the context of a service we provide. In other cases, we use the Personal Information as instructed by the provider or holder of the information, thereby becoming a processor.
The information we learn from customers helps us personalize and continually improve our services to better assist our customers. We collect Personal Information about you from your interactions with us and our CRED3 Services, and from certain third parties and other sources (such as the company or the provider providing you access to our CRED3 Services or from publicly available sources where permissible).
We obtain Personal Information from you through:
- Your interactions with us and our CRED3 Services. We collect communications, Content and other Personal Information you provide when you use our CRED3 Services. This includes signing up for a Dashboard, creating or sharing Content, providing Messages or other Content for the Dashboards of others, and messages and communications to us and others. The information you provide may provide us with metadata (information about the Content you provide such as the date or location of a photo, video, communication or file). It can also include information on what you are viewing or seeing when using certain features like camera or video services.
- Personal Information with special protections. You may choose to provide information to us about your political views, sexual orientation, health or religious ideologies when creating your Dashboard. This type of information as well as information about race, ethnicity, trade union membership or philosophical beliefs may be subject to special protections within certain countries. But through the CRED3 Services you may transmit your Dashboards with that information to others (“Recipients”).
- Information about Transactions. We collect information from you when you purchase or use our CRED3 Services, register for an event, request information or call us for support (please note that we may record or monitor our telephone calls for training, quality assurance and quality purposes). Typical information we store about you includes; name, postal address, shipping address, tax ID, credit card number, email address, bank account number (if supplied), telephone and fax numbers, etc.
- Personal Networks and People Connections. We collect information about the Dashboards, people, pages and accounts you browse, interact with or connect to. We collect contact information you choose to upload for reference requests or searching purposes in order to help you find people you may know or who also use our CRED3 Services.
- Personal Usage: CRED3 collects and analyzes information about how you use our CRED3 Services such as the type of Dashboard you purchase, what you choose to upload, other Dashboards you view, people or Dashboards you communicate with, how frequently you use our CRED3 Services and the duration of time you use our CRED3 Services.
We may also obtain device information from you when engage or use our CRED3 Services. This information may include:
- Device or System Attributes. This information relates to the device you are using to access our CRED3 Services or Dashboards. The type of operating system, software version, browser type, file names, plugins and storage space are all types of device information we may collect.
- Identifiers. Distinctive identifiers that classify your device may be collected. This includes unique identifiers, device ID’s and account data you sync.
- Device behaviors and operations. This information includes mouse movement, whether the Dashboard is in the foreground or background and Internet tab data.
- Network Information. Information regarding your mobile operator, ISP, time zone, language, device phone number and IP address are collected to help us monitor, protect and analyze our Website and CRED3 Services.
- Cookies and similar technologies included on our CRED3 Services. We obtain certain types of information when your web browser contacts our Website or CRED3 Services. We store this information in small data repositories called “cookies.” The data stored in cookies enable our systems to recognize your browser and to provide features customized to you. You may disable cookies.
We also may collect Personal Information about you from third parties such as:
- The person(s) or business arranging for you to access our Services (e.g. a company purchasing a business Dashboard) in order to set up a user account.
- An Organization you belong to that provides you access to our CRED3 Services (e.g., a company purchasing a business Dashboard).
- Other Companies may provide personal data about you to us when they have the lawful right to collect, use and share your data with us.
How we use your data
We use Personal Information to provide and improve CRED3 Services and for other purposes that are in our legitimate interests, as well as for compliance purposes. Personal Information about you is processed in order to:
- Personalize and Improve our CRED3 Services. The information you provide when using our CRED3 Services allows us to personalize features and content to things you may be interested in and make suggestions for you. To personalize our CRED3 Services to you we analyze your Dashboards, Content, Messages, other Contributions, connections, interests, activities and network. This includes analyzing how you interact with Dashboards, people or places.
- Gather information across Dashboards and devices. Information regarding your activities across different Dashboards you purchase or manage as well as devices you use may be analyzed in order to provide you with a more consistent experience across CRED3 Services as a whole.
- Communicate with you. We use the information you provide in order to communicate with you about our CRED3 Services, terms and policies. We may also use the information to respond to your questions or communications when you contact us.
- Assist in research and development. We use collected information in order to test, improve and develop our Dashboards and CRED3 Services. This may be done by collecting research, conducting surveys and troubleshooting new Dashboard features.
- Share ads and other sponsored content. In the event ads are used on our Website or in connection with CRED3 Services we will use your information in order to personalize ads, offers and content that may be of interest to you. Information about your interests and connections may be used to personalize ads.
- Measure and analyze third company services. Information you provide as well as your activity when using our CRED3 Services may be shared with advertisers and other businesses to measure the effectiveness of their ads and services. Such information is analyzed in order to discern the types of people who use their services and products, interact with their websites, click on their ads or purchase their services or products.
- To perform CRED3 Services. In this case personal information is processed to provide you with our Services.
Your Information may also be used or processed when:
- You give us your consent. If we need information that requires your consent, we will collect it separately and make it clear we are asking for your consent.
- It is for a legal obligation or compliance. Such as responding to a court order.
You are welcome to contact us to clarify our interests for processing and collecting your data or for further information.
Who your information will be shared with:
Information you share when using CRED3 Services:
- People and accounts, you choose to share and communicate with. When you choose to share or communicate information about yourself through use of our CRED3 Services you are choosing your audience. You pick who has access to your Dashboard, Messages or other Content, who can share your Dashboard, Messages and other Content, and if you are a Dashboard Owner whether you want your Dashboard to be public or private and whether you want your Dashboard to be available as a searchable Dashboard across our database.
- Public information. This information can be seen by anyone whether or not you are logged on or off our CRED3 Services and regardless if you have sent your Dashboard to them or not. Personal, professional or business Dashboards may be public or private. Other Dashboard users, businesses and you can send or access public information about anybody whether that person uses Dashboards or not. Public information may be seen, shared, accessed or downloaded through third-party services (search engines) and other websites that integrate with our CRED3 Services or Dashboards.
Information others share, send or resend about you.
- Messages and Other Contributions of Content. When asking for a recommendation, the person being asked (i.e., a Contributor) will be able to see some of your information and activity on CRED3 Services. They may choose to screenshot, download or share that information with others. Contributors will then send back a Recommendation or other Content about you that you may choose to upload or not. Contributors may be asked to provide other information that may be analyzed and/or used to create CREDibility scores for Messages, Content and Dashboards.
- Other Dashboard users may share content about you. Dashboard Owners may upload photos, videos, files or other Content that apply to you or include information about you. We do not control that. Business Dashboards may do the same. If you are uncomfortable about information being shared about you, please contact us to report the information.
Third-Party Websites and Services and Third-Party Integrations:
- Information may be shared when using third-party websites, software, or services that are integrated with or linked to CRED3 Services. If you share information on your Dashboard about outside sources, products or businesses the information may be shared or viewed by them. When you download third-party services, they may access your public Dashboards through our CRED3 Services and any information you provide.
Information we share with Third Parties.
We work with third parties in order to provide, improve and advance our CRED3 Services. An example of this is the software and technology from another company we use to perform the voice analytics. Such arrangements allow us to operate our company and provide better service. Your information will not be sold to others. Below is a list of third parties we may share information with:
- Third parties who use and assist us in analyzing our data and information. We sum up views, shares, sending of Dashboards and other statistics and analytics to provide people and businesses information with how people are viewing and using their Dashboards and information.
- Information is collected and shared in the aggregate with companies who can provide us with measurement and analytical data reports for us and third parties who work with us and for our customers.
- We may provide advertisers with data and reports regarding who is seeing their ads, how well ads are performing and how popular their ads are. Personal Information is not provided unless you give us explicit consent to do so. Aggregate numbers, general demographics and interest data is what is given to advertisers.
- Information and Content are provided to vendors, service providers and other contractors who help support and run CRED3 Services and our company. This includes analytics, technical infrastructure, customer service and payment processes. A third-party data center may be used to host software, data and information (including your Personal Information) for us.
- Information may be given to law enforcement in order to comply with the law or for legal requests when so ordered by a court.
What Security Measures Do We Use to Protect Your Data?
Our information security procedures and practices align with commercially reasonable standards and are reviewed regularly in order to meet the sensitivity nature of the Personal Information and services we handle.
SSL We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
Credit Card Numbers
We reveal only the last four digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing. We do not store Credit card numbers on our system.
It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.
Orders and Subscriptions
If you purchase a Dashboard or other services from us, we request certain Personal Information from you (e.g., on an order form). You must provide any necessary contact information (such as name and email) and financial information (such as credit card number, expiration date). We use this information for billing purposes. If we have trouble processing an order, we will use this information to contact you. We will also send you a confirmation of your order once it is complete.
Since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information you transmit to us or the CRED3 Services. There is no guarantee that information may not be accessed, copied, exposed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We are not responsible for the security, negligence or actions of third parties who may receive or have access to your information (including your Personal Information). We are not responsible for force majeure events. These risks are assumed by you.
You are responsible for maintaining the secrecy of your password and registration and account information, including any information for controlling access to your email communications at all times.
How Long Do We Keep Data?
Our data retention schedule for Personal Information is based on the following criteria:
- Length of time necessary to fulfill our service obligations.
- Length of time necessary to demonstrate we have fulfilled our obligations.
- Retention periods prescribed by the law.
- Length of time necessary to fulfill the purpose the information was collected for.
Your data will be stored until it is no longer necessary to provide you with our CRED3 Services, such as when an account is closed, or a Dashboard is deleted. When your account is closed, any Dashboards you own, and any other Content and information may be retained or deleted by us. Dashboards you manage, or information others have shared about you may be retained or deleted by us. Notwithstanding the foregoing, we have no obligation to store or retain any Dashboards, Content or information for more than one year.
Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request certain information regarding disclosure of their Personal Information to third parties for purposes of direct marketing. You may request further information about our compliance with California Civil Code Section 1798.83 at the following email address: compliance.officer@CRED3.com. Please note that we are only required to respond to one request per registrant each year, and we are not required to respond to requests made by means other than through this the address provided above.
Your Rights and Consent.
We respect the General Data Protection Regulation (GDPR) of Europe as well as other privacy laws to the extent they are applicable to you. These laws give you the right to request, restrict, rectify and erase your personal information. Under these laws your affirmative consent is necessary for the collection and processing of your data. The following is a list of rights you have under the GDPR:
- Subject Access Request: You have the right to ask us to confirm what personal data we hold in relation to you. We will provide you with the information requested within one month free of charge.
- Data portability: You have a right, in certain circumstances, to be given a copy of your personal data in a machine-readable format to facilitate a transfer of the data to another organization.
- Right to be forgotten: You have the general right to have your data erased. The right is restrictive and gives right to erasure when the data is:
- Out of date
- Processed on the basis of consent which has since been withdrawn
- Right to Rectification: You have a right to have inaccurate information about you corrected or removed.
- Right to Restriction of Processing: You have the right to have personal information about you used only for restricted purposes.
- Right to withdraw consent: You have the right to withdraw your consent to the processing and storage of your personal information at any time. Withdrawal of consent will not affect the lawfulness of our use of your information prior to your withdrawal.
The above-mentioned rights are not absolute and do not apply in every situation.
We may use your Personal Information for cross-marketing purposes, e.g., to advertise, market and promote other products, services, discounts and offers (including ours and those of others) to you and we may also engage third parties to assist us in doing so.
Third Parties for Direct Marketing
We may provide you with the opportunity to receive promotional offers from identified third parties through their direct marketing efforts. If you consent (opt-in), your Personal Information will be shared with the identified third parties to enable them to provide you with the offers you have requested. Any information that you provide may be transferred to these third parties or their websites. We have no responsibility or liability for these third parties or for their policies and practices or their websites. You should review any privacy policies posted on any of these websites before providing information to them.
On-line Forums, Blogs and Public Areas
Certain Personal Information collected from you or other users is disclosed as a matter of course as a result of those your or other users’ use of forums, blogs, reviews, and other public areas of the Website or CRED3 Services (“Public Areas”). Any information you submit or post to any Public Areas may be accessible by others and will be considered non-confidential public information without restrictions. We have no control over how others may use, store or disclose such information. YOU ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM YOUR VOLUNTARY DISCLOSURE OF PERSONAL INFORMATION.
Linked-In, Facebook and other Social Networking Accounts
We may offer search services to help users find other users and information about other users, but this will apply to you only if and to the extent that you are given the right to participate in searches.
If you provide any testimonials, references or other statements about us or our CRED3 Services, we may post those testimonials, references or other statements on the Website or in our own Dashboards or otherwise publish or disclose them. Once a testimonial, reference or other statement is received by us from you, we reserve the right to use your information for customer satisfaction purposes as well as to accelerate our sales activity and to promote our business.
Updating and Correcting Information
Please update your registration or account as necessary to keep it and your Personal Information current. Because we keep track of past transactions activities, you cannot delete or remove information associated with past transactions or activities. It may not be possible or practicable for us to completely or permanently delete all of your information from back-up or archival copies or devices, and we may decline to do so if asked.
This section only applies to information that we control. We are not in a position to update or correct or delete Messages or Content from others, only the information that you provide.
Enforcement; Legal Process
We reserve the right to disclose, use and preserve your information (including Personal Information) if we have a good faith belief that disclosure, use, or preservation of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or governmental order, or (ii) to investigate, enforce or protect our rights or the rights of others or the security of the Website, CRED3 Services, or any information.
DMCA Infringement Notifications, Notices of Violations of Website Terms of Service and Other Communications Directed to Us
3290 Mayflower Way
Lehi, Utah 84043