Privacy Policy
Updated June 2023
1. What's in this policy?
We at Cembla respect your privacy and are strongly committed to keeping secure any information we obtain from you or about you. This Policy is for when you're in the U.S. It tells you:
- what information we might collect about you
- how we might use that information
- when we might use your details to contact you
- what information of yours we might share with others
- your choices about the personal information you give us
This Policy describes our practices with respect to Personal Information we collect from or about you when you use our website, applications, and services (collectively, “Services”).
2. Personal information we collect
We'll give you details about why we need your personal information and how we'll use it before you begin, unless it's obvious. We collect personal information relating to you (“Personal Information”) as follows:
A. Information you give us
- Account Information: When you log in to our Services or create an account with us, we will collect information associated with your account if provided to us, including your name, contact information, account credentials, payment card information, and transaction history, (collectively, “Account Information”).
- User Content: When you use our Services, we collect Personal Information that is included in the input, which may include file uploads, or feedback that you provide to our Services (“Content”).
- Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send (“Communication Information”).
- Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, YouTube and LinkedIn. When you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your contact details (collectively, “Social Information”). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.
B. Information we receive automatically
When you visit, use, or interact with the Services, we receive the following information about your visit, use, or interactions (“Technical Information”), and may store this information in logs to improve our Service and prevent abuse.
- Device Data: Information about your device, such as IP (internet protocol) address, device ID, type of device, web browser, and operating system version. Information collected may depend on the type of device you use and its settings.
- Usage Data: We may automatically collect information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.
- Cookies: We use cookies to operate and administer our Services, and improve your experience. A “cookie” is a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website.
- Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.
3. How we use personal information
We have to have a valid reason to use your personal information. Sometimes we might ask your permission to do things, like when you sign up for a paid plan or join our waitlist. Other times, when you'd reasonably expect us to use your personal information, we don't ask your permission.
We may use Personal Information for the following purposes:
- To provide, administer, maintain and/or analyze the Services;
- To improve our Services, conduct research, and develop new services;
- To communicate with you, e.g. to update you on the Services if you joined our waitlist, or to deal with your requests, complaints and enquiries;
- To prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our systems;
- To carry out business transfers; and
- To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
4. When we'll contact you
We might send you marketing emails if you have provided us with your e-mail, e.g. by joining our waitlist or using our Services. You can ask us to stop at any time. Keep in mind, even if you unsubscribe from marketing emails, we may still contact you with important updates and information about our services.
- To update you on any changes to our policies, practices and Terms of Use;
- To check with you about any service or activity you’ve signed up for. For example, we might tell you if your account hasn't been used in a long time.
- To answer you when you’ve contacted us, or to respond to a comment or complaint
- We’ll never contact you to ask for your password.
5. When we share your personal information
In certain circumstances we may provide your Personal Information to third parties without further notice to you, unless required by the law:
- When you make something public, such as a comment on one of our social media accounts or on a blog post.
- When we use other companies (vendors and service providers) to power our services. In order for us to give you quality experiences and to understand how you’re using our services we may use other companies to process your personal information on our behalf. This may include hosting services, cloud services, and other information technology services providers, email communication software, and web analytics services, among others. We carefully select these companies, only share with them what they need to do the work, and do our best to make sure they keep your information secure, and access, process, or store Personal Information only in the course of performing their duties to us.
- When we do collaborative research. Cembla may collaborate with research partners and share data with them, which might include information we’ve collected about you. But we will be careful about what we share and what research partners can do with it.
- Sometimes by law we have to pass on your information to other organizations. We might also share your information in order to protect you or other people from harm, to protect and defend our rights and property, if we determine that there is a violation of our terms of use, to detect or prevent fraud or other illegal activity, or to protect the safety, security, and integrity of our products, employees, or users, or the public, or to protect against legal liability.
- If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Information and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
- We may disclose Personal Information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Cembla. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.
6. Your rights
Remember, you’re in control of your personal information. Depending on location, individuals may have certain statutory rights in relation to their Personal Information. For example, you may have the right to:
- Request access to a copy of your information and information relating to how it is processed.
- Delete your Personal Information from our records.
- Rectify or update your Personal Information if it is incorrect.
- Transfer your Personal Information to a third party (right to data portability).
- Restrict how we process your Personal Information, or request that we only use it for certain purposes.
- Withdraw your consent - where we rely on consent as the legal basis for processing at any time.
- Object to how we process your Personal Information.
- Opt out of future “sales” of your personal information.
- Lodge a complaint with your local data protection authority.
To exercise these rights, please send your request to contact@cembla.com.
7. Cookies & Tracking Technologies
A. What are cookies used for?
Cookies are small text files which are transferred to your computer or mobile when you visit a website or app. They serve a variety of purposes:
- Allowing us to remember information about you, so you don’t have to give it to us all the time.
- Keeping you signed in when you close your browser and re-open it at a later time.
- To help us understand how people are using our services, so we can make them better.
- To help us personalize our site to you by remembering your preferences and settings.
B. What are the types of cookies?
Some cookies are always on when you visit us, and you can’t turn them off unless you change your browser settings. These are “strictly necessary cookies”, and they're needed for our Services to operate correctly. If you turn them off, you may be unable to use our Services. (For example, you may not be able to stay logged in to your account.) In the future, we may also use functional, performance and advertising cookies to make your experience more enjoyable. You can switch these on or off at any time and you can always change your mind. We’ll only use them if you’ve agreed.
C. How long do cookies last?
Some are erased when you close the browser on your website or app. Others stay longer, sometimes forever, and are saved onto your device so that they’re there when you come back.
D. How do I control my cookies and tracking?
Strictly necessary cookies are always on when you visit us. For all other cookies, we’ll tell you about them and ask you to choose which cookies we can use. You can always change your mind later on. Another way to control some tracking is in the settings on your device.
8. Additional U.S. State Disclosures
The following table provides additional information about the categories of Personal Information we collect and how we disclose that information. You can read more about the Personal Information we collect in “Personal information we collect” above, how we use Personal Information in “How we use personal information” above, and how we retain Personal Information in “Security and Retention” below.
| Category of Personal Information | Disclosure of Personal Information |
|---|---|
| Identifiers, such as your name, contact details, IP address, and other device identifiers | We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions. |
| Commercial Information, such as your transaction history | We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions. |
| Network Activity Information, such as Content and how you interact with our Services | We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions. |
| Geolocation Data | We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions. |
| Your account login credentials and payment card information (Sensitive Personal Information) | We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions. |
To the extent provided for by local law and subject to applicable exceptions, individuals may have the following privacy rights in relation to their Personal Information:
- The right to know information about our processing of your Personal Information, including the specific pieces of Personal Information that we have collected from you;
- The right to request deletion of your Personal Information;
- The right to correct your Personal Information; and
- The right to be free from discrimination relating to the exercise of any of your privacy rights.
We don’t “sell” Personal Information or “share” Personal Information for cross-contextual behavioral advertising (as those terms are defined under applicable local law). We also don’t process sensitive Personal Information for the purposes of inferring characteristics about a consumer.
Exercising Your Rights. To the extent applicable under local law, you can exercise privacy rights described in this section by submitting a request to contact@cembla.com.
Verification. In order to protect your Personal Information from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information and proof of residency for verification. If we cannot verify your identity, we will not be able to honor your request.
Authorized Agents. You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us. Authorized agent requests can be submitted to contact@cembla.com.
Appeals. Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please send your request to contact@cembla.com.
9. Children
You must be 18 or over to register for an account. This is because Cembla is designed for the workplace, and our Service is not directed to children. Cembla does not knowingly collect Personal Information from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Information to Cembla through the Service, please email us at contact@cembla.com. We will investigate any notification and if appropriate, delete the Personal Information from our systems. If you are 16 or older, but under 18, you must have consent from your parent or guardian to use our Services.
10. Links to other websites
The Service may contain links to other websites not operated or controlled by Cembla, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
11. Security and Retention
We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. You should take special care in deciding what information you send to us via the Service or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites. We’ll retain your Personal Information for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.
12. Changes to the privacy policy
We update this policy sometimes. If we make important changes, like how we use your personal information, we’ll let you know. It might be a notice, an email or a message on our website. We will always link to an updated version on our website. If you don’t agree to the changes, then you can always stop using our services, delete your account and stop giving us any more personal information. We’d be sorry to see you go.
13. How to contact us
Please contact us at contact@cembla.com if you have any questions or concerns not already addressed in this Privacy Policy.