Last Updated: January 1, 2020

This Privacy Policy describes the information we process to support the SightPlan, Inc. software, mobile application and interaction points (collectively, the “Services”) and shall apply to your use of the Services. This Privacy Policy governs the manner in which SightPlan collects information from you (“User” or “you”) on the Services.

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Services, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services.

Accepting the privacy policy provides the authorization to transfer, store, and use your information in the United States and any other country where we operate. In some of these countries, such as those part of the European Union, privacy and data protection laws are in place regarding when government authorities may access data. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Services.

If you have any questions or comments about this Privacy Policy, please submit a request to privacy@sightplan.com.

Information We Collect

We collect information, including personal information, to provide better services to all our Users. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, information about your device, and certain metadata.

This Personal Information includes:

ï Name

ï Contact Information (Postal address(es), email address(es), telephone number(s), title)

ï Credentials such as username and password

ï App usage data

ï Information collected through cookies, pixel tags and other technologies

ï IP Address

ï Device information

ï Browser and device information

ï Profile picture

ï Location data

We ask that you not send us information defined as “Sensitive Personal Information” (e.g. information such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union memberships, genetic information, physical or mental health information, medical insurance data, or sexual orientation).

During the last twelve (12) months, we have collected the following categories of personal information from Users.

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We collect Personal Information in the following ways:

1. Information You Give to Us

You may choose to provide us with Personal Information about yourself, including your first and last name, email address, phone number, title, role, certifications, skill set, username, password, contact and notification preferences, location data, and any other information necessary for us to provide our Services. You may also provide us with Personal Information about yourself when you report a problem or have a question about our services.

We collect payment information for some SightPlan Services, such as first and last name, payment card number and banking details. This information is used solely for billing purposes and to fill your orders.

Please note that if you do not provide us with Personal Information, your ability to use certain aspects of our products and services may be limited.

2. Information We Obtain from Your Use of Our Services

We collect certain information automatically, such as your operating system version, browser type, language preference, and internet service provider. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; and cookies that uniquely identify your browser. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties.

Most mobile devices provide users with the ability to disable location services. These controls are most likely located in the device’s settings menu. If you have questions about how to disable your device’s services, we recommend you contact your mobile service carrier or your device manufacturer.

3. Location Data

When you use our Site and Services from a wireless device, we may solicit your permission to collect your location data. Some features within our application may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. The specificity of the location data collected may depend on a number of factors, including the device you are using (e.g. laptop, smartphone or tablet) and how you are connected to the Internet (e.g., via cable broadband connection, WiFi). If you enable location services for our Applications, we may collect location data periodically as you use or leave open our Application. We may associate such location data with Personal Information you provide to us. Depending on the platform you use to access our Applications (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your mobile device.

4. Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. By using the Sites, you agree that we can use these technologies as described in this policy. We use different types of cookies on our Sites to make your interaction with our Sites easy and meaningful – strictly necessary cookies, functionality cookies, analytics cookies, and advertising cookies. The Sites may include first-party cookies (i.e., cookies that send data directly to SightPlan and agents and contractors acting on our behalf, including cookies used to monitor, analyze, and administer the Sites) and third-party cookies (i.e., cookies that send data to our contractors for their commercial use).

We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google and similar analytics partners.

The technologies we use for this automatic data collection may include:

Cookies A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services.

Web Beacons Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

If you want to control the cookies that are placed on your computer or other device, you could view cookies stored on your hard drive, choose whether or not to permit cookies to be set by default by changing browser settings, or delete the cookies stored on your hard drive. Please be aware, however, that your decision to control cookies may affect your experience of our Sites – you may not be able to access all or parts of those Sites.

The main Web browsers allow you to change your cookie settings directly through their sites. These settings will typically be found in the ‘options’ or ‘preferences’ menu of your browser. In order to understand these settings, the following links may be helpful; otherwise you should use the ‘Help’ option in your browser for more details.

How We Use Information We Collect

We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

1. To inform you about services available from SightPlan;
2. To authorize access to our Services;
3. To provide you with Services;
4. To personalize user access and the Services;
5. To administer content, promotion, survey or other Site features;
6. To communicate about the Services and to deliver pertinent emails and SMS messages;
7. To analyze user trends and information about users’ use of the Services;
8. To improve our customer service;
9. To respond to and support customers regarding their use of the Site;
10. To comply with all applicable legal requirements.
11. To investigate possible fraud or other violations of our Terms of Service or this Privacy Policy and/or attempts to harm our Users.
    

We use the information we collect from our Services to provide, maintain, and improve them, to develop new services, and to protect our Company and our customers.

We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services. We can then develop statistics that help us understand how our visitors use our Services and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Our Legal Basis for Collecting Personal Information

Whenever we collect Personal Information from you, we may do so on the following legal bases:

1. Your consent to such collection and use;
2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our services and products;
3. Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:

• Product development and enhancement, where the processing enables SightPlan to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our customers, and to better understand how people interact with our Services;
• Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
• Fraud detection and prevention;
• Enhancement of our cybersecurity, including improving the security of our network and information systems; and
• General business operations and diligence;

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

Information We Share

We do not share Personal Information with companies, organizations and individuals outside of the Company unless one of the following circumstances applies:

• With your consent. We will share Personal Information with companies, organizations or individuals outside of SightPlan when we have your consent to do so.
• Your account administrators. We share Personal Information with account administrators who can configure and manage your account on behalf of you and your organization.
• Enterprise accounts. Your employer may offer you access to our Services. We will share Personal Information with your employer. Your employer can review and manage your use of such enterprise Services.
• For external processing. We provide Personal Information to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include marketing and business operations partners. It is our policy to only share Personal Information with contractors, payment processors, service providers and other third parties who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information. Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Services.
• For Legal Reasons. We will share Personal Information with companies, organizations or individuals outside of SightPlan if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, legal process or enforceable governmental request.
• Enforce applicable Terms of Service, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of SightPlan, our Users or the public as required or permitted by law.

• Business Transfers. As we continue to develop our business, we may buy, sell, or share assets in connection with, for example, a merger, acquisition, reorganization, sale of assets, or bankruptcy. In such transactions, Personal Information about our users is often a transferred business asset. In the event that SightPlan itself or substantially all of our assets are acquired, Personal Information about our users may be one of the transferred assets.
• Aggregate Use Information. We may share aggregate and anonymized/pseudonymized Personal Information to advertisers and other third parties in order to promote or describe use of the Services.

Your Failure to Provide Personal Information

Your provision of Personal Information is required in order to use certain parts of our services and our products. If you fail to provide such Personal Information, you may not be able to access and use our services, or parts of our services.

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Our Retention of Your Personal Information

We may retain your Personal Information for a period of time even after a SightPlan account is deactivated by an account administrator. Based on the nature of the Service, some information may remain in our records even after deactivation of the account, such as, but not limited to, historical task activity or billing information. We also may retain your Personal Information during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

Your Choices and Accessing, Updating or Deleting Your Personal Information

Whenever you use our services, we aim to provide you with choices about how we use your Personal Information. We also aim to provide you with access to your Personal Information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes.

Subject to applicable law, you may obtain a copy of Personal Information we maintain about you or you may update or correct inaccuracies in that information through your SightPlan online account or by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.

Your Rights With Respect to Personal Information

Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”) and some U.S. state laws including the California Consumer Protection Act and Nevada Privacy Law, provide you with certain rights in connection with Personal Information you have shared with us. A request to access your data will prompt an email request for additional information to verify who you are (if applicable) and an email that the request has been received and verified. Once information has been verified, an email with the requested information which will be completed within 45 days of verified consumer request, up to 135 days when reasonably necessary. If you are in one of these relevant jurisdictions, you may have the following rights:

1. The right to be informed. You are entitled to be informed of the use of your Personal Information. This Privacy Policy provides such information to you.
2. The right of access. You have the right to request a copy of your Personal Information which we hold about you.
3. The right of correction. You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
4. The right to be forgotten. You have the right to request us, at any time, to delete your Personal Information from our servers and to erase your Personal Information when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Information will likely impact your ability to use our services.
5. The right to object (opt-out). You have the right to opt-out of certain uses of your Personal Information, such as direct marketing, at any time.
6. The right to data portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Information stored on our servers / IT environment to another service provider’s servers / IT environment.
7. The right to refuse to be subjected to automated decision making, including profiling. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
8. The right to lodge a complaint with a supervisory authority.

California Privacy Rights – “Shine The Light” Requests

If you are a California resident, California Civil Code Section 1798.83 allows you to request information regarding the disclosure of your Personal Information to third parties for marketing purposes. SightPlan does not sell Personal Information to these third parties. You may request a list of our affiliates by contacting us at privacy@sightplan.com. You may make one request per calendar year. In your request, please include information that verifies that you are a resident of California. Please allow up to 45 days for a response to your request, up to 135 days when reasonably necessary.

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Changing or Deleting Your Information

You may update or correct information about yourself in your account or by emailing us at privacy@sightplan.com. Upon emailing us, we will send an email request for additional information to verify who you are (if applicable) and an email that the request has been received and verified. Once information has been verified, an email with the requested information which will be completed within 45 days of verified consumer request, up to 135 days when reasonably necessary. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.

We may contact you to request that you update your Personal Information on a regular basis to ensure its integrity for the purposes of ongoing data management.

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Our Opt-in/Opt-out Policy

By providing an email address on the SightPlan Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any service related notices, or to provide you with information about our events, invitations, or related educational information.

For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a user to submit or receive information, as the case may be.

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We currently provide the following opt-out opportunities:

1. At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.
2. At any time, you can contact us through privacy@sightplan.com or the address or telephone number provided below to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Information.
3. You may opt out of receiving text messages from SightPlan or a Customer, in the case of an End User, at any time, by replying with the word “STOP” to any text message you have received or by changing your communications preferences in your Service profile.

Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service related notices.

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Third Party Links

The Services may contain links to webpages operated by parties other than SightPlan. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites s) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party's website. SightPlan strongly recommends that each User review the third party's terms and policies.

International Transfer

We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Information. The information and Personal Information that we collect from you may be transferred to, and stored at, a destination outside of your jurisdiction, including the United States. It may also be processed by staff operating outside of your jurisdiction who works for us or for one of the organizations outlined in this Privacy Policy for in connection with the activities outlined in this Privacy Policy. By submitting your information and Personal Information and using the Site, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. If we transfer your Personal Information out of your jurisdiction, we will implement suitable safeguards to ensure that your Personal Information is protected.

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How We Protect Personal Information

SightPlan maintains administrative, technical and physical safeguards designed to protect the User's Personal Information and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we use commercially reasonable security measures such as encryption, firewalls, and transport layer security (TLS) or hypertext transfer protocol secure (HTTPS) to protect Personal Information.

If SightPlan collects account information for payment or credit, SightPlan will use the information only to complete the task for which the account information was offered.

Children

The Services is not intended for use by children. We do not intentionally gather Personal Information about visitors who are under the age of 16. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16, please contact us at privacy@sightplan.com. If we learn that we have inadvertently collected the Personal Information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

Changes to this Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or products, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

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Questions or concerns

SightPlan welcomes your feedback regarding this policy. If you have questions, comments or concerns, please contact us by email at privacy@sightplan.com or postal mail at:

SightPlan

P.O. Box 4308

Orlando, FL 32802-4308