PRIVACY STATEMENT

Last updated June 15, 2020

This Privacy Statement reflects Lassoo, Inc.’s (“Lassoo,” “we,” “our,” and “us”) commitment to privacy and data protection.

This Privacy Statement describes how we collect and process information about visitors to our websites (the “Site”), and individuals who use Lassoo’s data analytics platform (collectively the “Application Services”).

This Privacy Statement doesn’t apply to individuals whose information may be collected by Lassoo’s customers during their use of Lassoo’s Application Services.

SUMMARY OF KEY POINTS

We collect and use personal information and personal data from visitors to our Site, and users of our Application Services to provide Lassoo’s Application Services, to ensure those Services and our marketing materials are relevant and secure, and to conduct our business.

This Statement only applies to our collection and use of personal information and personal data, not to our customers’ use of Lassoo’s software to collect information or data. If you have questions about how our customers use Lassoo to collect information or data from your use of their services, you should contact them directly.
Lassoo collects personal information when you sign up for our Application Services, use our software, or share information with us. We also collect information about you using various technologies (including first- and third-party cookies, local browser storage, and other tracking technologies).
Lassoo uses the personal information and personal data you share or that we collect to provide our Application Services, to enhance our websites, to market Lassoo’s Application Services to you, for security purposes, and to comply with applicable laws, regulations, and other legal requirements. You can learn more about our use of personal information and personal data below.
Lassoo does not sell the personal information or personal data we collect. We do share that information and data with select third parties, but only in connection with providing our Application Services to our customers or when we have a legal basis for such sharing.
Lassoo uses cookies and other tracking technologies to track your use of our websites,, and your use of our Application Services. This Statement describes opportunities for controlling our use of these technologies.
Lassoo transfers personal information and personal data to the United States and other countries. These may be outside of the country or region you live in. We perform these transfers under certain model contractual provisions approved by the European Commission or by the Privacy Shield Framework.
Lassoo respects privacy rights, and we built our privacy compliance program with the European General Data Protection (the “GDPR”) and the California Consumer Privacy Act (the “CCPA”) firmly in mind.
Lassoo takes information security seriously, and its security controls are designed to safeguard personal information and personal data.
Lassoo has appointed a data protection officer, or “DPO.” You can contact our DPO at dpo@lassoo.io. You can also contact our privacy program by writing to compliance@lassoo.io.

APPLICATION OF OUR PRIVACY STATEMENT

Our Privacy Statement applies to Lassoo’s collection of information or data, and it is not intended to discuss the collection or use of personal information or personal data by a Customer’s use of the Application Services. It also does not apply to third-party websites, applications, or services reachable from our websites.

Lassoo collects information under the direction of its Customers in connection with its provision of the Application Services. Because a Customer’s collection or use of personal information is specific to their use and implementation of the Application Services, please consult a Customer’s privacy statement, privacy notice, or the written contract between a Customer and Lassoo for the Application Services for more information. We do not have a direct relationship with our customers’ customers.

If you are a customer of one of our Customers and would like more information on their use of your information, please contact the Customer that you interact with directly. If you have further questions about the application of our Privacy Statement, please contact our privacy program at compliance@lassoo.io.

INFORMATION WE COLLECT

We collect information, including personal information or personal data, when you visit our Sites or use our Application Services. We collect this information when you fill out forms or engage with us directly. We also collect this information via cookies, pixel tags, and certain software designed to interact with your computer or mobile device.

If you choose to share your information with us, we will collect the following information:

If you decide to create a Lassoo application account to use our Application Services, you must enter your first and last name, email address, and password or otherwise enter similar information into forms or surveys on our Site or Applications.
If you share information with us by entering it into your account–information like postal address, phone number, fax number, company name, and credit card payment information.
If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information for internal analytics purposes.

When you are asked to provide personal information or personal data, you may decline. And you may use application or device controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for specific products or features, those products or features may not be available or function correctly.

Information collected via technology

We automatically collect certain information via technology when you use the Site and Application Services:

IP Address, Location, Website Activity, and Browser Information. When you visit our Site or use our Applications, some information is automatically collected. We collect information about the type and language of the operating system (“OS”) running on your device, your internet protocol address (“IP Address”), the browser type you used during your visit, and the website you visited just before ours. We also collect information about which web-elements or objects you interact with, metadata about your activity on the Site, changes in your user state, and the duration of your visit.
Cookies. Lassoo collects information about your use of our Sites and Application Services via cookies.

Information obtained from third-party sources

When we collect information in connection with our business relationship with you, we may also purchase data about you from third parties. To be clear, we do not buy any data from any third parties in connection with our provision of the Application Services, and we never combine the purchased data with information about our customers’ end users or customers.

We protect information obtained from third parties according to the practices described in this Statement, plus any additional restrictions imposed by the source of the data. These third-party sources include, for example:

Applications and services, such as social networks that make users’ information available to others;
Service providers that help us determine your device’s location based on its IP Address to customize certain products to your physical location;
Partners with which we offer co-branded services or engage in joint marketing activities; and
Publicly available sources, such as open government databases or other information in the public domain.

Information created or generated

We infer new information from other information we collect, including using automated means to make information about your likely preferences or other characteristics. For example, we infer your city, state, and country location based on your IP Address.

COOKIES AND TRACKING TECHNOLOGIES

Cookies are small text files we send to individuals’ computers when they visit our Sites. Like nearly all websites, cookies make our Sites work more efficiently and effectively and help us improve our Site, the relevance of our marketing activities, and your experience while using the Site and Application Services.

Some of the cookies we use may provide us with information about you. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your computer, but it can contain other information as well.

We use cookies to see which areas and features are popular and to count visits to our Site. Most web browsers are set to accept cookies by default. If you prefer, you can choose to set your browser to remove cookies or to reject cookies.

If you want to delete or refuse cookies, this could affect certain features or functionality of our Site and could remove cookies used to opt-out of tracking for the Application Services.

Lassoo uses cookies and similar technologies for:

Site Authentication, Identity and Access Management, Security, and to Conduct Its Business. When you sign into the Site using your username and password, we store an encrypted cookie on your device. This cookie allows you to move from page to page within the Site without having to sign in again on each page. You can also save your sign-in information, so you do not have to sign in each time you return to the Site.
Marketing. Lassoo uses cookies and related technologies to measure your interest in Lassoo’s products and services so it can market those products and services to you.
Performance. Lassoo uses cookies for load balancing to help ensure that websites remain up and running.
Social Media. Portions of our Site include social media cookies or widgets, including those that enable users who are logged in to the social media service to share content via that service.
Site Experience. When you use or view certain content on the Site, Lassoo will store a cookie to ensure that you do not see the same content again or to save your interest preferences.
Opt-Out Cookie. When you opt-out of tracking on the Site, Lassoo will store a cookie that will block other cookies from being stored.

Some of the cookies we commonly use are listed below. This list is not exhaustive, but it is intended to illustrate the main reasons we typically set cookies. If you visit one of our sites, the Site may set some or all of the following cookies:

SessionID: Helps to authenticate you when you sign in to your account.

Certain third-parties may also set cookies on your computer or device when you visit our Sites. In some cases, that is because we have hired the third party to provide services on our behalf, such as payment processing for credit card billing. In other cases, it is because our web pages may contain content or ads from third parties, such as videos, news content, or ads delivered by other ad networks. Because your browser connects to those third parties’ web servers to retrieve that content, those third parties set and read their cookies on your device and may collect information about your online activities across websites or online services. To control cookies from those third parties, visit their sites. If you wish to opt-out of interest-based advertising, click here (or if located in the European Union, click here). Please note you will continue to receive generic ads. These third-party cookies may include:

Google
Stripe
Facebook
LinkedIn
Twitter

Pixel Tags

We also use “pixel tags” (also referred to as clear gifs, web beacons, or web bugs). Pixel tags are tiny graphic images with a unique identifier, similar in function to cookies (as noted below), that are used to track the online movements of web users. We embed these on our web pages but do not store them locally on your computer or phone. Pixel tags also allow us to see if emails we send are opened. We do this to ensure that we are sending only messages that are of interest to our Customers. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by pixel tags to our users’ personal information.

Browser Local Storage

We also store data locally on your device to enhance the user experience on our Site. For example, browser local storage allows us to save the state of your current page so that when you return at a later time or refresh the browser, the page will remain the same. We also use browser local storage to display “recently viewed items” or to mark your place in a tutorial, video, tooltip, or onboarding flow.

OUR USE OF COLLECTED INFORMATION

We use the personal information we collect for purposes described in this Privacy Statement or as otherwise disclosed to you. In general, we use the information we collect primarily to communicate with you, to market, provide, maintain, protect, and improve our current Application Services, and to develop new or enhanced versions of those Application Services.

Here is a list of how we use your information:

Facilitate the creation of and securing of your account on our network;
Identify you as a user in our Application Services;
Improve our Application Services, Site and how we operate our business;
Understand and enhance your experience using our Site and Application Services;
Provide and deliver products and services, including the Application Services, that you request, including securing, troubleshooting, and personalizing those products;
Respond to your comments or questions and for our Support team to provide service;
Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
Communicate with you about promotions, upcoming events and news about products and services offered by Lassoo and our selected partners, and for other marketing purposes of Lassoo;
Link or combine it with additional information we get from third parties, to help understand your needs and provide you with better service, as described under “Profiling” below; and
Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

Creation of De-Identified Data. We may create de-identified data records sourced or extracted from data connected to or associated with personal information by excluding information (such as your name) that makes the data personally identifiable to you. We use this de-identified data to analyze request and usage patterns so that we may enhance the content of our Application Services and improve our Application Services and Site navigation. We reserve the right to use de-identified data for any purpose and disclose de-identified data to third parties in our sole discretion where permitted by applicable law.

Profiling. When you interact with our Site by completing a form (such as a request for us to contact you, creation of an Account, request for information on pricing, or downloading content), we will collect your personal information and analyze your information to build individual profiles. We use third-party tools to help us make the profile by providing information about your business (like, company size and industry, for example). These profiles will be used to help us predict future interest in our Application Services. We base our profiling on your activity on the Site, and we update your profile in real-time based on your use of the Site.

We share personal information with your consent or as necessary to complete your transactions or provide the products you have requested or authorized. For example, when you provide payment information to make a purchase, we will share that information with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services. We also share personal information as follows:

Third-Party Service Providers. With third parties who work on our behalf for the purposes described in this Privacy Statement, provided that such third parties agree to provide at least the same level of privacy protection as required by this Privacy Statement. These services may include providing cloud computing infrastructure, website crash reporting, and providing customer support or account administration.
Lawful Requests. To comply with laws or to respond to lawful requests and legal process, provided that Lassoo will endeavor to notify you, where practical and permitted by applicable law or regulation, if Lassoo has received a lawful request for your information.
Protection of Rights and Property. To protect the rights and property of Lassoo, our agents, customers, and others, including to enforce our agreements and policies.
Emergency. In an emergency, including to protect the personal safety of any person.
Corporate Restructuring. For a corporate transaction (or negotiation of a corporate transaction) involving sale or transfer of all or a part of our business or assets (corporate transaction may include, for example, any merger, financing, acquisition, divestiture or dissolution transaction or proceeding). We may transfer your personal information in the event of an insolvency, bankruptcy, or receivership. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Statement.

PERSONAL INFORMATION SECURITY

Lassoo maintains appropriate and reasonable administrative, technical, and physical safeguards designed to help protect your personal information to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no transmission over the internet is 100% secure. We encourage you to protect your usernames and passwords to help prevent anyone from accessing or abusing your Application Services account(s), including not using the same passwords for the Application Services that you use with other accounts. If you have any questions about the security of your personal information, you can contact us at support@lassoo.io.

YOUR INFORMATION CHOICES AND CHANGES

In addition to the choices outlined in other parts of this Statement, you also have control over the following:

Access, Correction, and Deletion. If you wish to request access to or correction or deletion of personal information about you that we hold, you have some controls available to you from the “Account Settings” portion of the Application Services. You can also contact our Privacy Program at compliance@lassoo.io or our Data Protection Officer at dpo@lassoo.io. However, to the extent permitted by applicable law, we reserve the right to charge a fee or decline requests that are unreasonable or excessive, where providing the information would be prohibited by law or could adversely affect the privacy or other rights of another person, or where we are unable to authenticate you as the person to whom the information relates.
Email Communications. You may opt-out of receiving promotional or marketing emails from Lassoo by following the instructions in those emails. If you opt-out, we may still send you non-promotional emails, such as emails about your Lassoo projects or our ongoing business relationship.
Application(s). You can stop all collection of information by our Application(s) by uninstalling the Application(s).
Do Not Track Signals. Some web browsers may transmit signals instructing websites and other online services not to track information. In our opinion, no standard governs what, if anything, websites should do if they receive these signals. Lassoo currently does not respond to such browser signals or similar mechanisms instructing not to track information. If and when a standard is established, we may revise our position on responding to these signals. Third parties may collect personal information about your online activities over time and across sites when you visit our Site or use the Lassoo Service.
Social Media Widgets. As noted above, our website may include social media features, such as the Facebook and LinkedIn button or interactive mini-programs that run on our website. 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 correctly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy statement or notice of the third party providing it.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), beginning January 2020, you have certain rights with respect to that information. In particular, you have a right to request that we provide you with the following information:

The categories and specific pieces of personal information we have collected about you;
The categories of sources from which we collect personal information;
The purposes for collecting, using, or selling personal information;
The categories of third parties with which we share personal information;
For companies that disclose personal information for a business purpose, the categories of personal information disclosed about you for a business purpose; and
For companies that “sell” personal information, the categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

To make such requests, contact us at compliance@lassoo.io or the other contact information set out below. Note that we have provided the information described in (2)-(5) in this privacy statement. Concerning (6) above, we do not “sell” personal information as defined by the CCPA.

You also have a right to request that we delete personal information under certain circumstances, subject to several exceptions. Finally, you have a right not to be discriminated against for exercising rights set out in the CCPA.

EUROPEAN DATA PROTECTION RIGHTS

If the processing of personal information about you is subject to European Union data protection law, you have certain rights with respect to that information:

You can request access to, and rectification or erasure of, personal information;
If any automated processing of personal data is done with your consent or under a contract with you, you have a right to transfer or receive a copy of the personal information in a usable and portable format;
If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
You can to object to, or obtain a restriction of, the processing of personal information under certain circumstances; and
For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests or contact our Data Protection Officer (“DPO”) at dpo@lassoo.io or at the contact information set out below. We process data as a processor on behalf of our Customers. If you are a customer of our Customer, you should put requests to them or contact them. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

We may rely on different lawful bases for collecting and processing personal information about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

LOCATION OF PERSONAL DATA

The personal information we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. Currently, we primarily use data centers in the United States. The storage location is chosen to operate efficiently and improve performance. We take steps designed to ensure that the personal information we collect under this Statement is processed according to the provisions of this Statement and applicable law wherever the data is located.

Location of Processing European Personal Data. We transfer personal information from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protection, please visit https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

RETENTION OF PERSONAL DATA

We retain personal information or personal data for as long as necessary to provide the products and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. These needs can vary for different information types in the context of different products. Accordingly, our actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the information, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

CHANGES TO THIS STATEMENT

Lassoo may change this Statement from time to time to reflect changes in our offerings, how we collect, use, or disclose personal information, or applicable law. If we make any changes to this Statement, we will change the “Last Updated” date above. If we make any material changes, we will provide notice or obtain consent regarding such modifications as may be required by law.

HOW TO CONTACT US

If you have a privacy concern, complaint, or a question for Lassoo please contact our privacy program at compliance@lassoo.io. If you have concerns, complaints, or questions please contact our DPOs at dpo@lassoo.io.