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Privacy Policy

Last Updated August 16, 2024 
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Protecting your privacy is fundamental to the way Expedition Data Inc., doing business as Team Engine (“Team Engine”, “we”, “us”, or “our”), conducts business. This Privacy Policy explains how we may collect, use, and disclose your personal information when you access and use our online products and services that link to this Privacy Policy (including, our website, www.teamengine.io), (the “Site”), our marketing activities, our live events, and other activities described in this Privacy Policy) (collectively, the “Online Services”). This Privacy Policy does not apply to your use of third-party sites linked to this website. 

This Privacy Policy may change from time to time. We will make note of the changes on our website and your continued access to the Online Services is deemed to be your acceptance of those changes, so we encourage you to check back periodically for updates.

You can jump to particular topics by going to the headings below:

  • What is Personal Information?
  • Personal Information Collected from You
  • How we Use Personal Information
  • Disclosure of Personal Information
  • Your Choices
  • Information Security
  • How We Retain Your Personal Information
  • International Data Transfers and EU-U.S. Data Privacy Framework
  • Binding Arbitration
  • Complaints
  • Other Important Information
  • GDPR Transparency Statement
  • Children’s Policy
  • Changes to Our Privacy Policy
  • Contact Information
  • Supplemental European Privacy Rights Statement

What is Personal Information? 

The term “personal information” in this Privacy Policy refers to any information or data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular identifiable natural person or household, or any other information or data that constitutes “personal information”, “personal data,” or “personally identifiable information.”An identifiable natural person, or “Data Subject,” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Personal Information Collected from You

We collect the following information in the course of providing you these services: 

Table 1
Context Types of Information Primary Purpose for Collection and Use of Information
Client Information
We collect the names, usernames, and contact data of our clients and their employees with whom we may interact.  
We are executing on a contractual obligation in contacting our clients and communicating with them concerning normal business administration such as billing, registration, and our services.
Client and User Account Information
We collect personal information from our clients and users of our Online Services when they create an account to access and use the Online Services. This information could include business contact data such as name, email address, title, company information, phone number and password for the Online Services.
We are executing on a contractual obligation by providing account-related functionalities to our users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. 
Client Applicant 
Our clients use our Online Services to collect information on applicants and their employees. This may include information such as name, contact information, work history, resume, EEO information, veteran status, and disability status.
We are executing on a contractual obligation to provide our clients with our Online Services to assist them in tracking applicants. Our clients obtain individual consent from individual applicants to process this information and are responsible for managing this information in accordance with applicable local laws and regulations.
Employee Information
Our clients use our Online Services to collect information on and communicate with their employees. This may include information such as name, contact information, work times and locations, work details, work duties, and other information relevant to an individual’s role and/or employment with our client(s).
We are executing on a contractual obligation to provide our clients and their employees with our Online Services. Our clients have a legitimate interest to manage their workforce and employees, and they are responsible for managing this information in accordance with all applicable local laws and regulations.
Cookies and First-Party Tracking
We use cookies and clear GIFs. “Cookies” are small pieces of data that a website sends to a computer’s hard drive while a website is viewed. 
We have a legitimate interest in making our website operate efficiently and improving our marketing efforts and Online Services.
Cookies and Third-Party Tracking
We participate in behavior-based advertising and the gathering of analytics. This means that a third- party uses technology (e.g., a cookie) to collect data about your use of our website so that they can provide us with website and user analytics, as well as for the purposes of advertising products and services tailored to your interests on our website, or on other websites. 
We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics in improving our marketing efforts. For additional information on our use of cookies, please review our Cookie Policy. Additionally, you can manage your cookie consent preferences in the cookie consent manager via our website’s cookie banner.
Email Interconnectivity
If you receive an email from us, we may use certain tools to capture data related to when you open our message or click on any links or banners contained within. 
We have a legitimate interest in understanding how you interact with our communications to you.
Employment
If you apply for a job posting or become an employee of Team Engine, we collect the information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number or Personal Public Service Number. Providing this information is required for employment.
We use information about current employees to fulfill our contract of employment or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We are executing on a contractual obligation in using your information to have efficient staffing and workforce operations.
Feedback and Support
We collect personal information from you contained in any inquiry you submit to us regarding the Online Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support and chat requests, or to report an issue. When you communicate with us through our live support chat or over the phone, your messages and calls may be recorded and analyzed for training, quality control, and for sales and marketing purposes. During such interactions, we will notify you of the recording via either voice prompt or script.
We have a legitimate interest in receiving and acting upon, your feedback, issues, or inquiries.
Mailing List and Demo Requests
When you sign up for one of our blogs, mailing lists, or webinars, or when you submit a demo request, we collect contact information such as your name, email address and company affiliation. 
We share information about our Online Services with individuals that consent to receive such information. 
Order Placement 
We collect your name, billing address, e-mail address, phone number, and use a third-party PCI compliant service to process your payment card number when you place an order. Specifically, we use Stripe for payment processing.
We use your data to perform our contract to provide you with Online Services. For questions about how Stripe processes your data, please refer to their Privacy Policy: https://stripe.com/privacy.
Payment Information
We collect payment and billing information when you register for certain paid Online Services, such as our Web App. For example, we ask you to designate a billing representative, including name and contact information, upon registration. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.
We are executing on a contractual obligation in obtaining payments for certain Online Services.
Promotions
Promotions, incentives, or giveaways may be made available by us or third parties from time to time. You do not have to participate in these, however, if you choose to participate, you may be asked to disclose some personal information. Additionally, at the time of entering the promotion, we will disclose in the promotion’s materials specific terms and conditions regarding how your personal information will be used. Please do not participate in any promotion if you do not agree to such usage.
We obtain consent to share information about our Online Services and providing incentives to our customers.
Surveys
When you participate in a survey, we collect data that you provide through the survey. If the survey is provided by a third-party service provider, the third-party’s privacy policy applies to the collection, use, and disclosure of your information.
We obtain consent for any surveys and use them to gain an understanding of your opinions and collecting data relevant to our organization.
Website Interactions
We use technology to monitor how you interact with our Online Services. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.
We have a legitimate interest in understanding how you interact with our Online Services to better improve them, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Social Media
When an individual interacts with our Services through various social media networks, such as when someone follows us or shares our content on Facebook, Twitter (X), LinkedIn, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The information we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. 
We use this information to update and maintain the page to provide you with content and features of our Services, as well as to improve our product outreach. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We have a legitimate interest and/or may obtain your consent to collect this information.
Web Logs, Device and Usage Information
We collect information, including your device and browser type, operating system, operating system and browser version, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), derived IP address location, domain name, click-activity, referring website, and/or a date/time stamp for visitors. Additionally, we collect user account activity to include when an activity is completed, the type of activity taken, and the related data for the activity (for example, if a user sends a message, etc.).
We have a legitimate interest in monitoring our networks and visitors to our Online Services. Among other things, it helps us to monitor performance and to understand which of our Online Services and features are the most popular.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check. 

Team Engine has committed to complying with laws applicable to individual privacy and privacy breach notification that are enacted in the various jurisdictions in which it operates and offers its Online Services. Collectively referred to as "Data Protection Laws."

If you are located in:
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- the European Economic Area, UK, or Switzerland, please also see the Supplemental European Privacy Statement below.
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- One of the United States with legislation protecting individual privacy, please also see Your Choices below

How We Use Personal Information

We use the personal information which you provide to us to perform our Online Services as outlined in this Privacy Policy.  When you are our prospective or current business client of our Web App, we use personal information about you and your employees to:

  • deliver the Site and Web App;
  • carry out "Know Your Client" checks and screenings prior to starting a new engagement;
  • carry out client communications, services, billing, and administration;
  • configure our Online Services and your dashboard access, and other professional services that you may request;
  • secure client feedback;
  • deal with client complaints and requests;
  • create marketing materials such as white papers, case studies, and social media content; or
  • contacting and marketing to our clients.

We also process personal information about our clients/prospective clients and employees of our clients/prospective clients to:

  • contact our prospects and clients in relation to current, future, and proposed engagements;
  • send our prospects and clients newsletters, know-how, promotional material, and other marketing communications; or
  • invite our prospects and clients to events (and arrange and administer those events).

When you are a visitor to our Site, our Web App, attend our live events, or request marketing information, we may use your personal information to:

  • monitor the performance of our Site and Web App, analyze trends, usage, and activities in connection with our Site;  
  • deliver targeted advertising where permitted by applicable law; or 
  • respond to your requests, deliver information (including marketing information) to you based on your needs and interest.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you sign up for our Web App, we may collect your information to complete that transaction, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about the Online Services. If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected for, we will request your consent, unless there is an exception which applies under applicable law, such as those listed in the section below. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations.

Disclosure of Personal Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information we collect from you: (1) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our clients or others (2) to our authorized service providers such as our contractors and other third parties we use to support our business; (3) to fulfill the purpose for which you provide it; (4) to a buyer or other successor in the event of a sale, merger, reorganization or transfer of some or all of our business or assets; (5) for any other purpose disclosed by us when you provide the information; (6) to comply with any court order, law or legal process, including responding to any government or regulatory request; (7) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections; or (8) with your consent. We do not sell your personal information or otherwise share personal information with third parties for direct marketing purposes.

Your Choices

You can make the following choices regarding your personal information:

Right to Access Your Personal Information
You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. 
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‍Right to Data Portability
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You may have the right to obtain a copy of the personal information that you previously provided.  We will provide this information in a portable format, to the extent technically feasible, readily usable format that allows you to transmit your personal information to another controller without hindrance, where the processing is carried out by automated means. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
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‍Right to make Changes to Your Personal Information
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We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law.
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‍Right to Deletion of Your Personal Information
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Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
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‍Right to Object to Certain Processing
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You may object to our use or disclosure of your personal information by contacting us at the address described below.
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‍Online Tracking
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We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
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‍Promotional Emails
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You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can
stop receiving promotional emails by following the unsubscribe instructions in the e-mails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
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‍Promotional Text Messages
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If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
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‍Revocation Of Consent
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If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

Please address written requests and questions about your rights to support@teamengine.io.

Note that, as required by law, we will require you to prove your identity.  We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  We will require verification that you provided the authorized agent permission to make a request on your behalf.  You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.  If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of the following information to the request: A completed notarized statement executed by you and the consumer indicating that you have the authorization to act on the consumer’s behalf.

Information Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access and disclosure. The Team Engine platform is hosted on Amazon Web Services’ (AWS) Cloud Infrastructure located in secure facilities in the United States, which comply with international best practice security certifications. We also maintain physical, electronic, and procedural safeguards to limit access to your nonpublic personal information. For more information about our security practices and certifications, please visit our Trust Center.

The use of, and access to, your personal information by us is restricted to only authorized individuals who need to know that information to provide services to you, and who have received training about the importance of protecting personal information. Our service providers and business partners are also contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purposes. Unfortunately, no method of transmission of information via the internet or electronic storage is completely secure.

Although we take reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our website or other electronic means. Any electronic transmission of personal information is at your own risk. In the event that we are required by law to inform you of a breach of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law. 

How we Retain Your Personal Information

Typically, personal information collected by Team Engine will be kept for as long as the user’s account remains active or until the user deletes the information. The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use and/or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Team Engine may also anonymize your personal information (so that it can no longer be associated with you) for research, statistical or other business purposes. We may use this aggregated, anonymized, or de-personalized data indefinitely. We may retain personal information for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. You can request further details of retention periods for different aspects of your personal information by contacting us at support@teamengine.io.

International Data Transfers and EU-U.S. Data Privacy Framework

We are a global business, with our primary location in the US. The personal information (or “personal data”) which we collect from you may be transferred to a destination outside the EEA or the UK, namely to the US where it will be stored. You acknowledge the transfer to, and storing, or processing outside of the EEA or UK of your personal information as set out in this Privacy Policy.

Team Engine complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and 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. Team Engine has certified to the U.S. Department of Commerce that it adheres 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 and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Team Engine has certified to the U.S. Department of Commerce that it adheres 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 privacy policy 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, go here.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Team Engine commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

Team Engine is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf.  Team Engine complies with the EU-U.S. DPF Principles for onward transfers of personal data, including the onward transfer liability provisions.

Binding Arbitration

If you are a resident of the European Union, the United Kingdom, or Switzerland, you have the possibility, under certain conditions, to invoke binding arbitration to address disputes. This option is available after other dispute resolution mechanisms have been exhausted. Team Engine is obligated to arbitrate claims and adhere to the terms set forth in Annex I of the Data Privacy Framework (DPF) Principles. To invoke binding arbitration, an individual must deliver notice to us and follow the procedures and conditions outlined in Annex I of the DPF Principles.

The Federal Trade Commission has jurisdiction over Team Engine’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  In certain situations, Team Engine may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

‍European Economic Area (EEA) and the United Kingdom (UK)
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If you are located in the EEA, or the UK, we comply with applicable laws to provide an adequate level of data protection for the transfer of your personal data to the US. 

‍Transfers outside the EEA and UK
Where applicable law requires that a data transfer have legal mechanism, we use one or more of the following: Standard Contractual Clauses with a data recipient outside the EEA or the UK (or additionally, in the case of the UK, the International Data Transfer Agreement (IDTA) or Addendum to the Standard Contractual Clauses issued by the ICO), verification that the recipient has implemented Binding Corporate Rules, or other legal method available to us under applicable law.  

Complaints

If you are a resident of the EEA, and believe we process your information in scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Office of the Data Protection Commissioner. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. To exercise your privacy rights set forth in this Privacy Notice, you may contact us as set forth in the Contact us section.

Other Important Information

Third-Party Providers
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Some applications and services may be embedded within our Site or Web App, or linked from our Site or Web App. These third parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our Site or Web App or navigate away from our Site or Web App. These third parties may also have privacy policies that differ from ours. For example, they may collect personal information about your online activities over time and across different websites, and other online services, and may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-parties or their privacy practices, and this Privacy Policy does not apply to any third-party website or service you may access through our website. If you have any questions about a third-party provider’s privacy policies or advertising, you should contact the responsible provider directly.

‍Non-Personal Information
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This Privacy Policy does not restrict our collection, use or disclosure of any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual.

‍Accessibility
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If you have a disability and require an alternative format to this Privacy Policy, please email us at: support@teamengine.io so that we may provide you with a more suitable format.

GDPR Transparency Statement

‍If you are dissatisfied with Team Engine’s transparency regarding data protection and data privacy, you have the right to contact the Data Protection Authority in the Member State of the European Union of your habitual residence, place of work or place of the alleged infringement, or with the Information Commissioner’s Office for UK residents if you consider that your personal data is not processed in accordance with the GDPR/UK GDPR. Please see the appropriate list and contact information below:

EU Data Protection Authorities‍

‍UK Information Commissioner’s Office (ICO)

‍Data Protection and Information Commissioner (FDPIC)

If you are a Swiss Data Subject: As per the Swiss Civil Code and the FADP, you may lodge a civil claim in case of personality rights’ infringements, in particular, regarding the exercise of your rights of access, rectification, and object but also regarding infringements related to data privacy principles.

Children’s Policy

Because we care about the safety and privacy of children online, our Site and its services are not intended for use of any kind by children under the age of 18. Additionally, we do not knowingly contact or collect personal information from children under 18.  For more information on how to protect children’s privacy online, please visit the FTC. https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy.

Changes to Our Privacy Policy

We will post any changes we make to this Privacy Notice on our website. If we make material changes to how we treat personal information we collect from you, we may notify you by email or through a notice on our website homepage, but any changes are effective when posted online and are deemed accepted by you when you continue to use or access the Site, WebApp or the Online Services. The date this Privacy Policy was last revised is identified above. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Policy on our website to check for any changes.

Contact Information

If you have questions or comments about this Privacy Policy, please email us at support@teamengine.io or contact us by mail by providing a written request to Team Engine at 4845 Pearl East Cir Ste 118, PMB 48042, Boulder, Colorado 80301-6112.

Supplemental European Privacy Rights Statement

If you are a resident of the European Economic Area, we rely on our legitimate interest, contractual relationship, and you consent as described in this Privacy Policy to process your personal information. Additionally, subject to any exemptions as provided by law, you may have certain rights regarding the personal information we maintain about you. We offer you certain choices about what personal information we collect from you, how we use that information, and how we communicate with you. If at any time you wish to exercise your rights, please reach out to us in accordance with the “Contact Us” section below.

According to the GDPR, UK GDPR, and FADP, you have the following rights:

‍Right of Access
If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information along with certain other details. If you require additional copies, we may charge a reasonable fee.

‍Right to Rectification‍If your personal information is inaccurate or incomplete, you may be entitled to ask that we correct or complete it.‍Right to Erasure
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You may ask us to erase your personal information in some circumstances, such as where we no longer need it, or you withdraw your consent (where applicable) and where there is no other legal basis for processing.

‍Right to Restrict ProcessingYou may ask us to restrict or ‘block’ the processing of your personal information in certain circumstances, such as if you contest its accuracy or object to us processing it.

Right to Data Portability
You may have the right to obtain your personal information from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and if the processing is carried out by automated means.

Right to Object
You may ask us at any time to stop processing your personal information, and we will do so: (a) if we are relying on a legitimate interest to process your personal information, unless we demonstrate compelling legitimate grounds for the processing or your data is needed to establish, exercise, or defend legal claims; or (b) we are processing your personal information for direct marketing and, in such case, we may keep minimum information about you (for example, in a suppression list) as necessary for our and your legitimate interest to ensure your opt out choices are respected in the future and to comply with data protection laws.

Right to Withdraw Consent
If we rely on your consent to process your personal information, you may have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.

Right to lodge a Complaint
If you have a concern about our privacy practices, including the way we handled your personal information, you can report it to the data protection authority that is authorized to hear those concerns.

Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply. We will not discriminate against you for exercising such rights. 

Except as described in this Policy or provided for under applicable privacy laws, there is no charge to exercise your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking in account the administrative costs of providing the information or taking the action requested; or refuse to act on the request and notify you of the reason for refusing the request.

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