Privacy policy

Effective Date: January 25, 2024

Overview

Telepath Data, Inc. dba Seventh Sense (“Seventh Sense”, “we”, “our”, or “us”) knows that you care about how your personally identifiable information is used and shared - and we take your privacy seriously. This privacy notice ("Privacy Notice") applies to both our websites (“Websites”), including www.theseventhsense.com, and our Subscription Service (“Service”), including our associated mobile applications (“Mobile Apps”). This explains our treatment of personally identifiable information ("Personal Data") that you submit, or Seventh Sense otherwise gathers, when you access or use the Service.

Processing activities covered

This Privacy Notice applies to the following processing activities:
  • Visiting our Website which display or link through to this Privacy Notice;
  • Visiting our offices;
  • Receiving communications from us, including emails, texts or faxes;
  • Registering for our events;
  • Participating in community and open source development projects;
  • Using or accessing the Service or the Mobile Apps.

Our Website may contain links to other websites, applications and services maintained by third parties. The information practices of such other services are governed by the third-party privacy notices, which we encourage you to review to better understand those third parties’ privacy practices. 

What Personal Data do we collect?

We collect Personal Data in the following ways:

  • Information you give us: For example, you must provide us your name and email address when you register to use the Service or Mobile Apps. Later, you’ll have to provide us with authorization for various services we gather data from.
  • Information you provide to our payment processor on our behalf: We use a payment processor to facilitate collecting payment for the Services. Recurly, our payment processor, stores your subscription and credit card information. Recurly’s privacy policy can be found at https://recurly.com/legal/privacy/.
  • From our customers: Our customers provide us Personal Data about the end users or recipients they communicate with. For example, after a customer has created an account within the Service, they will create a “connector” to integrate their marketing automation and/or email system with the Service. We will collect Personal Data from the connector and use it to build profiles for the customer.
  • From our service providers: Our services providers may provide us with Personal Data about how our customers interact with our Services or Mobile Apps.
  • From third party businesses: We may receive information from third party analytics providers (e.g., Google Analytics) or third-party sales and marketing providers regarding interaction with our Website, emails or other marketing.
  • Information we collect automatically: When you interact with our Website, our email messages or other marketing materials, or our Services, we collect information automatically through cookies or other automatic tracking technologies.

What device and usage data we process?

Information we gather from your use of our Service, Mobile Application or Website. As a part of our commitment to deliver the best possible services, we gather a variety of information on an ongoing basis. This information includes details such as what pages you might have visited, details about errors you may have experienced, how long various operations took, etc. We gather this information in a variety of ways, including:

Logs

We automatically generate and store certain information, including whenever you interact with the Service, Website or Mobile Application. Such information may include your account id, IP address, domain server, and type of Internet browser. This information helps us, among other things, analyze trends and administer the Service.

Cookies, web beacons and other tracking technologies.

We use cookies and similar technologies such as web beacons, tags and Javascript alone or in conjunction with cookies to compile information about usage of our Website, Services, Mobile Apps and your interaction with emails from us.
When you visit our Website or log into our Services, our servers or an authorized third party may place a cookie on your browser, which can collect information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track overall usage, determine areas that you prefer, make your usage easier by recognizing you and providing you with a customized experience.


We use both session-based and persistent cookies. Session cookies exist only during one session and disappear from your computer 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 Website, Mobile Application or Service. To opt-out from tracking by Google Analytics, please use the specific opt-out mechanism as indicated below.


We also use web beacons on our websites. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. Such tracking technologies are used to operate and improve our Website and email communications and track the clicking of links or opening of emails.


The following sets out how we use different categories of cookies and similar technologies, as well as information on your options for managing the settings for the data collection by these technologies:

 

Type of Cookies

Description

Managing Settings

Required cookies

Required cookies enable you to navigate our websites and use their features, such as accessing secure areas of the websites.

If you have chosen to identify yourself to us, we may place on your browser a cookie that allows us to uniquely identify you when you are logged into the websites and to process your online transactions and requests.

Because required cookies are essential to operate the websites there is no option to opt out of these cookies.

Functional Cookies

Functional cookies allow us to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features.

Functional cookies may also be used to improve how our websites function and to help us provide you with more relevant messages, including marketing communications. These cookies collect information about how our websites are used, including which pages are viewed most often.

We may use our own technology or third party technology to track and analyze usage and volume statistical information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.

In particular, we use Google Analytics ("Google Analytics"), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA as our processor. Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the websites visitors have come from, and the pages they visit. This information is used by us to improve our websites.

To manage the use of functional cookies on our websites, consult your individual browser settings for cookies. Note that opting out may impact the functionality you receive when using our websites.


To opt out from data collection by Google Analytics, you can download and install a browser add-on, which is available here.


To learn how to control functional cookies using your browser settings click here.

 

 

Purposes for which we process Personal Data and the legal basis on which we rely

We use Personal Data for the following purposes:

  • Providing our Service and the Mobile Apps: To provide our Service, the Mobile Apps, including to provide customer support, to process payments, and to fulfill our obligations under the applicable terms of use/service.
  • To provide our Website: To provide, operate and administer our Website, including to provide you with content you access and request (e.g., download of certain content from our websites).
  • Secure our Service, Mobile Apps, and Website: To monitor and secure our Service, Mobile Apps and Website, including to verify your account and activity, investigate suspicious activity or violations of our terms and policies, or as otherwise necessary for to secure our Services, Mobile Apps and Website, and the systems and applications that support them;
  • Managing user registrations: to manage your user account.
  • Handling contact and user support requests: If you fill out a “Contact Me” web form, request user support, or if you contact us by other means, we will process your Personal Data in order to respond to you, and otherwise to fulfill the purposes for which it was provided.
  • Managing payments: To collect and process payments.
  • Developing and improving our Services, Mobile Apps and Websites: To analyze trends, track your usage and interactions, to gather feedback about our products and services, and to develop new products and services;  
  • Sending marketing communications: To send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interests to conduct direct marketing.
  • Complying with legal obligations: To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws, to protect property or personal safety, to enforce our rights, to pursue remedies available to us and limit our damages, to comply with a judicial proceedings, court order or legal process, and/or to respond to lawful requests.
  • With your Consent: For other purposes that are disclosed to you at the time of collection or with your consent.

Who do we share Personal Data with?

We may share your Personal Data with the following recipients:

  • Customers: We share information about a customer’s end user or end recipient’s with that customer.
  • Our contracted service providers: We share information with service providers that provide services such as IT and system administration and hosting, authentication, credit card processing, research and analytics, marketing, customer support and data enrichment.
  • Professional Service Providers: We share information with professional service providers such as lawyers, bankers, auditors and insurers.
  • Third-party businesses: We may share information with certain third-party businesses. These businesses collect information for their own business purpose. For example, these businesses may be third party marketing applications (e.g., Google Analytics).
  • Other third parties: We also share Personal Data with the following third parties as we deem necessary, including legal authorities, when required by any applicable law, rule regulation, subpoena, or other legal process, in connection with the negotiation or execution of a merger or sale of our business, or to prevent illegal, harmful, fraudulent, or damaging activities.

Your Choices & Preferences

  • Marketing Communications: If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from us by clicking on the “unsubscribe” link located on the bottom of our marketing emails, by replying or texting ‘STOP’ if you receive SMS communications, or by turning off push notifications on our apps on your device. Additionally, you may unsubscribe here or by contacting us using the information in the “Contacting Us" section below. Please note that opting out of marketing communications does not opt you out of receiving business communications related to your current relationship with us, such as information about your subscriptions or event registrations, service announcements or security information.
  • Cookies: You may opt-out from the collection of device and usage data (see "What device and usage data we process" section above) by managing your cookies at the individual browser level. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the website.
  • Account Information: If you have registered for an account with us, you may generally update your user settings, profile, organization’s settings or event registration by logging into the applicable website with your username and password and editing your settings or profile. To update your billing information, discontinue your account, and/or request return or deletion of your Personal Data and other information associated with your account, please use the information in the “Contacting Us” section to contact us. 

European Data Privacy Rights 

Data Subject Rights

If you are a resident of the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, you are entitled to certain rights. These rights include:

  • Right of access and/or portability: You have the right to access any Personal Data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider.
  • Right of erasure: In certain circumstances, you have the right to the erasure of Personal Data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected).
  • Right to object to processing: In certain circumstances, you have the right to request that we stop processing your Personal Data and/or stop sending you marketing communications.
  • Right to rectification: You have the right to require us to correct any inaccurate or incomplete Personal Data.
  • Right to restrict processing: You have the right to request that we restrict processing of your Personal Data in certain circumstances (for example, where you believe that the Personal Data we hold about you is not accurate or lawfully held).

To submit a request to exercise your rights, please contact us in accordance with the “Contacting Us” section below. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honor your request.

If you are not affiliated with our customer and submit a request related to the Service, we will direct you to submit a request to exercise your rights directly with our customer.

We may have a reason under the law why we do not have to comply with your request or may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

We process Personal Data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide the Service; and (3) as necessary for our legitimate interests where those interests do not override your fundamental rights and freedom related to data privacy. We may also process Personal Data as necessary to comply with legal obligations. Personal Data we collect may be transferred to, and stored, and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities, as described above.

Individuals that reside in the EEA, UK, or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

Cross-border Transfer

Your Personal Data may be collected, transferred to and stored by us in the United States and by our affiliates in other countries where we operate. To facilitate data transfers from the EU to other countries, we make use of the European Commission-approved standard contractual data protection clauses, the Data Privacy Framework, or other appropriate legal mechanisms to safeguard the transfer. 

Data Privacy Framework Notice

We comply with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce.  We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of Personal Data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  We have certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this Data Privacy Framework Notice and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

We are responsible for the processing of Personal Data we receive under the DPF and subsequently transfer to a third party acting as an agent on our behalf.  We comply with the DPF Principles for all onward transfers of Personal Data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over our compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.  In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, we commit to refer unresolved complaints concerning our handling of Non-HR Personal Data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to Judicial Arbitration and Mediation Services, Inc., an alternative dispute resolution provider based in the United States. For clarity, Non-HR data includes all Personal Data processed by us on behalf of its customers. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of Judicial Arbitration and Mediation Services, Inc. are provided at no cost to you.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.

Children

Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us as described in the “Contacting Us” section below and we will take steps to delete such Personal Data from our systems.

Retention of Your Personal Data

We may retain your Personal Data for a period of time consistent with the original purpose of collection (see "Purposes for which we process Personal Data and on what legal basis" section above). We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of your Personal Data, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means, as well as the applicable legal requirements (such as applicable statutes of limitation).

After expiry of the retention periods, your Personal Data will be deleted. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of the data.

Security

We take precautions including organizational, technical, and physical measures, to help safeguard against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the Personal Data we process or use.

While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us via the “Contacting Us” section below.

Changes to this Privacy Notice

We will update this Privacy Notice from time to time to reflect changes in our practices, technology, legal requirements and other factors. If we do, we will update the “effective date” at the top of this Privacy Notice. If we make an update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.

We encourage you to periodically review this Privacy Notice to stay informed about our collection, processing and sharing of your Personal Data.

Contacting Us

If you have any questions or concerns regarding our privacy practices, please send us a detailed message to privacy@telepathdata.com

or:

Telepath Data, Inc. (dba Seventh Sense),

2017 N Dinwiddie Street,

Arlington, VA 22207