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Privacy Policy

Effective Date: September 12, 2023

Your privacy is valued and respected at Sorcero, Inc. (“we”, “our”, “us”). This Privacy Policy (“Privacy Policy”) describes the types of information, including Personal Data, that we gather from you when you use our website (including https://www.sorcero.com) and services (our “Service”), as well as your choices regarding use and disclosure of your Personal Data. As used in this Privacy Policy, the term “Personal Data” (“Personal Data”) means information that identifies you directly or indirectly, by reference to identifier(s) such as your name, identification number, online identifier or one or more factors specific to your physical, physiological, genetic, economic, cultural or social identity.

By accessing our Service, you agree to be bound by this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Service. Each time you use our Service, the current version of the Privacy Policy will apply. Accordingly, whenever you use our Service, you should check the date of this Privacy Policy (which appears at the top) and review any changes since the last version. This Privacy Policy is applicable to all Service visitors, registered users, and all other users of our Service.

Further, you acknowledge that this Privacy Policy is part of our Terms of Service, which is incorporated by reference, and by accessing or using our Service, you agree to be bound by the Terms of Service. If you do not agree to our Terms of Service, do not access or use our Service.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

 

Personal Data Collected by Sorcero 

When you use our Service, Sorcero collects information (i) that you knowingly and voluntarily provide when you use our Service (such as through forms or profile screens) including registration/account setup information, and (ii) that we are able to collect from your web browser, cookies and other similar technologies.

 

1. Personal Data that you Knowingly and Willingly Provide 

Sorcero collects the information that you knowingly and voluntarily provide when you use our Service (such as through web forms or profile screens), including registration/account setup information, profile details, payment information, and ratings information. We primarily use this information to provide you the Service. You can choose not to provide us with certain Personal Data, but then you may not be able to take advantage of our Service or other available features we offer. The information that we collect and use may include the following kinds of Personal Data:

  • First and Last Name
  • Email Address
  • Telephone Number
  • Login name, screen name, nick name, handle or any other identifier that permits the physical or online contacting of a specific individual

 

2. Personal Data that we collect from you

Web Browser. 

Sorcero collects information that is sent to us automatically by your web browser. Sorcero may use this information to generate aggregate statistics of your usage of our Service. This information typically includes details about your:

  • IP Address
  • Browser Type
  • Browser Plug-In Details
  • Operating System
  • Local Time Zone
  • Date and Time of Each Visitor Request (e.g. web pages selected and time spent on each page) Referring Site and/or Search Engine
  • Device Type (e.g. desktop, laptop, tablet, phone, etc.)
  • Screen Size, Color, Depth, and System Fonts
  • Language Preference

Sorcero may use this data for various business purposes such as providing customer service, fraud prevention, market research, and improving our Service. The information we receive depends on the settings on your browser. Please check your browser if you want to learn what information your browser sends or how to change your settings.

 

Cookies. 

Sorcero may obtain information about you by installing “cookies” on your computer’s hard drive. We use cookies to collect statistical information about the ways visitors use our Service including which pages they visit, which links they use, and how long they stay on each page. Sorcero also may use cookies to create a database of your previous choices and preferences, saving you time and effort.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. If you limit or disable the use of cookies when you visit Sorcero, you may be unable to use the full functionality of our Service. For more information about cookies, visit: http://www.allaboutcookies.org.

 

How Is Your Personal Data Used?

We will only process your Personal Data, including sharing it with third parties, where (1) you have provided your consent which can be withdrawn at any time, (2) the processing is necessary for the performance of a contract to which you are a party, (3) we are required by law, (4) processing is required to protect your vital interests or those of another person, or (5) processing is necessary for the purposes of our legitimate commercial interests, except where such interests are overridden by your rights and interests.

We may use Personal Data we collect about you on its own or combine it with other information we have about you to:

  • To create user accounts and/or profiles through registration;
  • Perform internal operations, such as tracking and improving the effectiveness of our website, mobile experience, and marketing efforts;
  • Provide product and/or Service fulfillment, such as creating accounts, managing purchases, payments, and more;
  • Personalize user experiences, such as remembering your settings and preferences for things like language, font size, etc.;
  • Provide support;
  • Resolve disputes between users and/or a user and the company as set forth in our Terms of Service;
  • Use the location of your mobile device to prevent fraud or deliver other location-based services that you may request;
  • Conduct surveys;
  • Conduct research;
  • Receive feedback;
  • Conduct audits;
  • Provide information to our suppliers;
  • Provide information to our representatives and/or advisors, such as our attorneys, accountants, and others to help us comply with legal, accounting, or security requirements;
  • Transfer your information, such as to servers outside of the United States, or as part of a merger or sale of the business;
  • Protect the rights, safety, and information of our members, third parties, as well as our own. This includes fraud prevention, business or product recalls, prosecuting and defending a court arbitration or similar proceeding, and more;
  • Comply with legal requirements. We may also disclose your Personal Data as otherwise set forth in this Privacy Policy, as permitted by law, or with your consent.

 

Who Can Access the Information We Collect?

We will only transfer your Personal Data to trusted third parties who provide sufficient guarantees in respect of the technical and organizational security measures governing the processing to be carried out and who can demonstrate a commitment to compliance with those measures. In the case of the onward transfer of personal information to a third party acting as a controller, Sorcero will enter into a contract with the third party controller that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by you and that third party controller will provide the same level of protection as the Data Privacy Framework (DPF) Principles and will notify Sorcero if it makes a determination that it can no longer meet this obligation. Sorcero recognizes potential liability in cases of onward transfer to third parties. The contract shall provide that when such a determination is made the third party controller ceases processing or takes other reasonable and appropriate steps to remediate their processing of any Personal Data on our behalf.

Where third parties are processing Personal Data on our behalf, they will be required to agree, by contractual means or otherwise, to process the Personal Data in accordance with the applicable law. This contract will stipulate, amongst other things, that the third party and its representative shall act only on our instructions, or as permitted by law.

 

Agents. We employ other companies and individuals to perform functions on our behalf. Examples of such functions include fulfilling orders, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing technical support, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. We share our users’ Personal Data with these agents as we deem necessary for such third parties to perform their functions.

 

Employees. Only authorized employees have access to your Personal Data.

 

Affiliates. When you are asked for information while on our Service, you are sharing that information with Sorcero, and our various affiliates, unless specifically stated otherwise. As a result of this sharing, you may receive communications from any of our affiliates:

 

Affiliates and Subsidiaries. Sorcero may share Personal Data with our corporate subsidiaries and affiliates, such a Sorcero Learning, Inc. for uses consistent with this Privacy Policy. Sorcero Learning, Inc. will also adhere to all Data Privacy Framework (DPF) Principles.

 

Affiliated Businesses We Control. We may share your Personal Data with the affiliated businesses we control to make sure that your experience with us is as seamless as possible and that you have the full benefit of our offerings. The use of your Personal Data by such controlled affiliates remains subject to this Privacy Policy.

 

Authorized Business Partners. These include agents, contractors, vendors, licensors, resellers, system integrators, etc. Sorcero, our affiliates, and our business partners may share this Personal Data with each other and use it consistent with this Privacy Policy.

 

Authorized Service Providers. An authorized service provider (“ASP”) is an individual or entity that is permitted to service products that are still covered by warranties held by another entity. Service provided by anyone other than an authorized service provider will generally render a warranty void. We may share information with such ASPs to perform services on our behalf. When we disclose your Personal Data to these persons, it is subject to agreements that require these individuals and entities to process your Personal Data only on our instructions and in compliance with this Privacy Policy.

 

To Comply with a Legal Process, Protect Sorcero, or Enforce our Rights. We may release your Personal Data when it is necessary to (i) conform to legal requirements or comply with legal process; (ii) enforce or apply our conditions of use and other agreements (iii) protect the rights, safety or property of Sorcero, our affiliates, service providers, our users or the public, or (iv) prevent a crime or protect national security (including exchanging information with other companies and organizations for fraud protection and credit risk reduction).

 

As Part of a Merger or Sale of Business. We may disclose your Personal Data in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

 

Selling of Personal Information

We will not sell your Personal Data to third parties for their use without your consent.

Children Online Protection

Our Service is not directed to children under the age of 18; if you are not 18 years or older, do not use our Service.

We do not knowingly collect Personal Data from children under the age of 13. If we learn that Personal Data of persons less than 13 years-of-age has been collected through our Service, we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child or a minor under the age of 13 has posted, submitted or otherwise communicated Personal Data to our Service without your consent, then you may alert us at support@sorcero.com so that we may take appropriate action to remove the minor’s Personal Data from our systems.

Links to Third Party Services

Our Service may contain links to third party websites, applications and services not operated by us. These links are provided as a service and do not imply any endorsement by Sorcero of the activities or content of these sites, applications or services nor any association with their operators. Sorcero is not responsible for the privacy policies or practices of any third party including websites or services directly linked to our Service. We encourage you to review the privacy policies of any third party site that you link from our Service.

Social Media Features & Widgets

You can log in to our Service using sign-in services such as Auth0, Okta, Google Accounts, Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain Personal Data with us such as your name and email address to pre-populate our sign up form. Services like Google, LinkedIn, and Facebook Connect give you the option to post information about your activities on this Service to your profile page to share with others within your network. Social media features and widgets are either hosted by a third party or hosted directly on our Service. Your interactions with these features are governed by the privacy policy of the company providing it.

Security, Storage, & Retention

  1. Security : We take reasonable technical and organizational precautions to protect the confidentiality, security and integrity of your Personal Data. Although we use security measures to help protect your Personal Data against loss, misuse or unauthorized disclosure, we cannot guarantee the security of information transmitted to us over the Internet. While we strive to use commercially acceptable means to protect your Personal Data, there is no guarantee that information may not be accessed, disclosed, altered or destroyed.
  2. Storage : The Personal Data that you provide to us is generally stored on Sorcero’s servers located in the United States. If you are located in another jurisdiction, you should be aware that once your Personal Data is submitted through our Service, it may be transferred to our servers in the United States and that the United States currently does not have uniform data protection laws in place.
  3. Retention : We will retain your information for as long as needed to provide you with our Service. If you wish to cancel your account or request that we no longer use your information to provide you the Service, contact us at support@sorcero.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Sorcero International Users

We are headquartered in the United States. Your Personal Data may be accessed by us or transferred to us in the United States or to our affiliates, partners, merchants, or service providers who are located worldwide. If you are visiting our Service from outside the United States, be aware that your information may be transferred to, stored, and processed in the United States where our servers are located, and our central database is operated. By using our Service, you consent to any transfer of this information.

We will protect the privacy and security of Personal Data according to this privacy statement, regardless of where it is processed or stored; however, you explicitly acknowledge and consent to the fact that Personal Data stored or processed in the United States will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of your Personal Data.

Sorcero complies with the EU-U.S. Data Privacy Framework (DPF) Framework and Swiss-U.S. Data Privacy Framework (DPF) Framework, (“https://www.dataprivacyframework.gov”), as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  Sorcero has certified to the Department of Commerce that it adheres to the Data Privacy Framework (DPF) Principles.  If there is any conflict between the terms in this privacy policy and the Data Privacy Framework (DPF) Principles, the Data Privacy Framework (DPF) Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit: https://www.dataprivacyframework.gov/. You can see the Data Privacy Framework (DPF) List, here: “https://www.dataprivacyframework.gov/list”). Sorcero has a commitment to subject to the Principles all personal data received from EU and Swiss individuals, in reliance on the Data Privacy Framework (DPF).

See Sorcero’s registration and status with the Data Privacy Framework (DPF) Program, here: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt00000008xQMAAY&status=Active

 

Sorcero Changes to this Privacy Policy

We reserve the right to update or modify this Privacy Policy from time to time. If we make any material changes to this Privacy Policy or the way we use, share or collect Personal Data, we will notify you by revising the “Effective Date” at the top of this Privacy Policy, prominently posting an announcement of the changes on our Service, or sending an email to the email address you most recently provided us (unless we do not have such an email address) prior to the new policy taking effect. Users are bound by any changes to the Privacy Policy when he or she uses our Service after notice of such changes has been communicated. We encourage you to review this Privacy Policy regularly to ensure that you are familiar with Sorcero’s current practices.

Correction & Removal

If any of the information that we have about you is incorrect, or you wish to have information (including Personal Data) removed from our records, please contact us at support@sorcero.com. We will respond to such inquiries within fifteen (15) business days.

If neither Sorcero nor our dispute resolution provider resolves your complaint, you may have the possibility to engage in binding arbitration through the Data Privacy Framework (DPF) Panel.

 

Dispute Resolution

Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Sorcero, Inc.’s internal processes, Sorcero, Inc. has agreed to participate in the VeraSafe DPF Dispute Resolution Program. Subject to the terms of the Data Privacy Framework (DPF) Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Data Privacy Framework (DPF) Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

Marketing

By consenting to this Privacy Policy, you agree to receive marketing materials from us. If Personal Data is collected by us for marketing purposes, we will usually inform you before collecting your data or sharing it for third party purposes. You can prevent the processing of your Personal Data for these purposes by checking certain boxes on the forms we used to collect your personal data. You may opt-out from the use of your Personal Data for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you. Additionally, if you prefer not to receive marketing messages from us, please let us know by clicking on the unsubscribe link within any marketing message that you receive, or by sending a message to us at support@sorcero.com.

 

Your California Rights

FOR RESIDENTS OF CALIFORNIA ONLY. Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your Personal Data with third parties. If you reside in California and have provided your Personal Data to Sorcero, you may request information about our disclosures of certain categories of Personal Data to third parties for direct marketing purposes. Such requests must be submitted to us at support@sorcero.com. Within thirty (30) days of receiving such a request, we will provide a list of the categories of Personal Data disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this Section.

Your European Union and Swiss Rights

FOR INDIVIDUALS IN THE EUROPEAN UNION AND SWITZERLAND. Under the General Data Protection Regulation 2016/679, you have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Data. You can also exercise the right by contacting us using the Contact Us section on our Site.

In certain circumstances, you have the right to:

  • request access to any Personal Data we hold about you (“Subject Access Request”) as well as related information, including the recipients or categories of recipients to whom the Personal Data has been shared;
  • obtain without undue delay the completion of any incomplete Personal Data or the rectification of any inaccurate Personal Data we hold about you;
  • request Personal Data held about you to be deleted provided the Personal Data is not required by Sorcero for compliance with a legal obligation under Swiss, European or Member State law or for the establishment, exercise or defense of a legal claim;
  • prevent or restrict processing of your Personal Data, except to the extent processing is required for the establishment, exercise or defense of legal claims; and
  • request transfer of Personal Data directly to a third party where this is technically feasible.

In addition, where you believe that the Sorcero has not complied with its obligations under this Privacy Notice or European Union or Swiss law, you have the right to make a complaint to an EU Data Protection Authority and the Swiss Federal Data Protection and Information Commissioner. For human resources data relating to European Union or Swiss individuals, Sorcero commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities regarding human resources data transferred from the EU and Switzerland in the context of the employment relationship.

All Personal Data collected by Sorcero and domiciled in the United States is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Sorcero has a requirement to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements

You can exercise any of these rights by contacting us using the Contact Us section on our Site.

 

Privacy Inquiries

If you have any questions or concerns about this Privacy Policy or our privacy practices please contact us as at support@sorcero.com.