Last Updated: 05/18/2020

1. Introduction

INFONEEDLE, INC (either “INFONEEDLE,” “we,” or “us”) provides virtual events platform using its ENGAGEZ brand. INFONEEDLE collects, uses, discloses, transfers, and otherwise processes data, including any information that may be used, either alone or in combination with other information, to personally identify a natural person (“Personal Data”), in several ways, as described herein. INFONEEDLE is committed to protecting and respecting your privacy. This Privacy Policy (“Policy”), together with our Master Subscription Agreement and any other document referred to therein, describes how INFONEEDLE treats personal data when you, the user, access the INFONEEDLE platform, mobile application or website located at https://engagez.com or https://www.engagez.net (the “ENGAGEZ”).

We require certain Personal Data for use of our products and services.  If you choose not to provide any requested Personal Data, you may be unable to use our services.

Our Site may contain links to third-partys and services that are not owned or controlled by INFONEEDLE. We are not responsible for the privacy practices or the content of third party websites, services and advertisements, and you visit them at your own risk. This Policy only applies to Personal Data collected by INFONEEDLE, and does not apply to any Personal Data collected by any third party. We encourage you to familiarize yourself with privacy policies applicable to any websites and services operated by third parties as we are not responsible for the privacy practices of any third parties.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING ENGAGEZ, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND AND AGREE TO BE BOUND BY ALL OF THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT ACCESS OR USE ENGAGEZ.

2. Type of Information INFONEEDLE Collects.

We may receive and/or collect information, including Personal Data, in the following ways:

1. Personal Data in Connection with User Account Registration and User Account-Related Activities – Certain areas and features of ENGAGEZ, such as registration of a user account or profile for purposes of participation in a virtual event hosted by us, entering protected web pages, or opting to receive further information about INFONEEDLE products or services may require you to provide INFONEEDLE with certain Personal Data such as your name, email address, address, company name, job title, phone number, and other business or contact information. No transaction payment data is collected or stored by INFONEEDLE. The foregoing types of Personal Data may also be collected by the company sponsoring a virtual event hosted by us (a “Sponsor”) that you register for or participate in. INFONEEDLE is not responsible for Sponsor’s privacy practices involving your Personal Data. We encourage you to review the Sponsor’s privacy policy in advance of registering for or participating in a virtual event.
2. Your Activities On and Use of ENGAGEZ- INFONEEDLE may automatically collect information about your activities on and/or usage of ENGAGEZ. Activity information we automatically collect may include which web pages you visited, the Uniform Resource Locator (“URL”) identifying the website you came from or visit after you leave ENGAGEZ, the average time you spent on ENGAGEZ, information, including Personal Data, you’ve previously shared with INFONEEDLE, your domain, your computer’s Internet Protocol(“IP”) address, etc. (defined below). In addition, if you are logged into a password protected area, we may associate that information with your account. To accomplish this we may use the following:
3. IP Address – The IP address is the numerical label associated with the location of your computing device.
4. Web Beacons – Web Beacons are strings of code placed on a webpage in conjunction with Cookies (defined below). Web Beacons are able to track the number of users that visit a website and, in conjunction with cookies, identify the IP address and personalize the website experience. Web Beacons may also be used to collect anonymous and/or aggregate, unidentifiable information such as how many users attended a virtual event.

iii. Cookies – In some cases, INFONEEDLE may use HTTP cookies (web cookies, Internet cookies, browser cookies), Flash Cookies (cookies that are not related to a specific browser, further described below), clear GIFs (a.k.a. web beacons), and log file information (a file that records either events that occur in an operating system or other software runs, or messages between different users of a communication software) to:

(a) store information so that you will not have to reenter it during your visit or the next time you visit the event;

(b) provide customer, personalized content and information; or

(c) monitor aggregate metrics such as the total number of visitors, pages, viewed, and similar information. A cookie is a small amount of data, which often includes a unique identifier that is placed on your computer or on your mobile phone/tablet (collectively referred to herein as a “device”) browser from a website’s computer and is stored on your device’s hard drive. There are two different types of cookies: session cookies and persistent cookies. Session cookies are held temporarily and disappear when you close your browser. Persistent cookies may be used by your browser on subsequent visits. Cookies are widely used to provide certain features of websites, to make websites perform more efficiently, and to provide information to the owners of the website. Each INFONEEDLE event and/or webcast can send its own cookie to your browser if your browser’s preferences allow it. For events and webcasts, cookies record information about your online preferences and allow us to present content to your interests. Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued or not to receive cookies at any time. If you do not opt in to receive cookies and/or set your device to not receive cookies, certain personalized features cannot be provided to you, and accordingly, you may not be able to take full advantage of ENGAGEZ’ features.

1. Third-Party Cookies – You may be presented with cookies from third-party websites and providers that are not related to INFONEEDLE. For example, when you view a webpage with content embedded from a third-party provider, you may be presented with cookies from such a provider. INFONEEDLE does not control the dissemination of these third-party cookies. In general, you should check the third-party websites for more information regarding that third-party’s data practices and policies. In addition, INFONEEDLE provides an optional single sign-on using social networks including, but not limited to, Facebook, and LinkedIn. If you are logging into an INFONEEDLE event using a social network credential, the applicable third party, and not INFONEEDLE, will set cookies. INFONEEDLE does not control or have any access to the cookie information these social networks may set.
2. Local Storage – . INFONEEDLE uses browser local storage on personal computers and mobile devices to deliver its services.
3. Content – Any Personal Data or content that you voluntarily upload or otherwise disclose while on ENGAGEZ (such as, through use of an INFONEEDLE blog), including but not limited to the information disclosed on discussion boards, in messages and chat areas, within a profile page, or images or any other content you provide (“Content”), becomes publicly available and can be collected and used by others. In addition, if you are given the ability to log into your account with any social networking website, or post Content on such site, another third-party website, or through ENGAGEZ, such Content may be made available to other parties and associated with your Personal Data. Personal Data uploaded in association with any INFONEEDLE event is only used for and shared with the particular customer of INFONEEDLE for that event. Data that is in an aggregate, de-identified form that is no longer considered Personal Data and does not allow the identification of individual users may be used by INFONEEDLE for purposes of research and analysis.
4. Purposes for Which INFONEEDLE Collects Information.
5. Operation, Maintenance, and Flagging – If you submit Personal Data through ENGAGEZ, INFONEEDLE may use it to operate, maintain, and provide you with the general and personalized features and functionality of ENGAGEZ, provide you with the INFONEEDLE products and services you request or order, complete transactions, or communicate with you. We may also use such Personal Data to process any flagging activity or correspondence you send to us.
6. Messaging – Your user account registration information may be displayed in password-protected areas to other users. If you choose to receive an email from INFONEEDLE, we may use clear GIFs (a.k.a. web beacons) in HTML-based emails sent to you to track which emails are opened by recipients.
7. No Commercial Marketing – INFONEEDLE will not use your email address or other Personal Data to send commercial or marketing messages for our benefit without your consent, except as part of a specific program or feature or other business relationship for which you opt-in. We will not share your Personal Data with third-party marketers.
8. Non-Marketing or Administrative Uses – INFONEEDLE may use your email address without your consent for non-marketing or administrative purposes, such as notifying you for customer service reasons.
9. Quality & Features – INFONEEDLE may use Personal Data and certain non-personally identifiable information in furtherance of its legitimate interest to improve the quality and design of ENGAGEZ and to create new features, promotions, functionality, and services by storing, tracking, analyzing, and processing user preferences and trends, as well as user activity and communications, to improve or personalize your experience, to improve or manage ENGAGEZ or products and services, to provide features available on ENGAGEZ, to operate and improve our products and services, for market research, to analyze ENGAGEZ, and to ensure the technical functionality and security of ENGAGEZ.
10. URLs & IP Address – When you visit ENGAGEZ through a referral, INFONEEDLE automatically receives the URL of the site from which you came. We also receive the Internet protocol (IP) address of your computer, your computer operating system and type of web browser you are using, as well as the name of your Internet service provider (“ISP”). This information may be used by INFONEEDLE in furtherance of its legitimate interests to analyze overall trends, determine the domain from which you came, who visits ENGAGEZ, to understand the needs of ENGAGEZ visitors, or to help us improve the INFONEEDLE service.
11. Access to Your Information.

You have the following rights with respect to the Personal Data we hold about you:

1. The right to know what Personal Data we hold about you. If you would like to know what personal data we hold about you, please contact us at [email protected];
2. The right to correct, amend, change, and delete Personal Data about you. If you have questions regarding the correction, deletion, or updating of the personal data we hold about you, please contact us at [email protected];
3. The right to opt-out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages and SMS-messages, give you the option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us at [email protected]; and
4. If you are a resident of the European Union (the :EU”), you may have the right to lodge a complaint relating to our processing of personal data about with a data protection authority (“DPA”) of the EU Member State in which you reside.
5. Sharing of Personal Data With Third Parties.

We share Personal Data about you with third parties for the purposes detailed below. Please note that this Policy does not apply to third parties, INFONEEDLE is not responsible for the privacy practices of third parties, and that you should consult the respective privacy policies of third parties for more information on their practices.

1. To Conduct Our Business – INFONEEDLE shares Personal Data with your consent or as necessary with third-party service providers to complete any transaction or provide any product or service requested or authorized. INFONEEDLE also shares Personal Data with third-party service providers, suppliers, or agents working with INFONEEDLE or on INFONEEDLE’s behalf, such as data storage service providers, human resources service providers, marketing automation services, and data analysis companies, including Google.
2. Law Enforcement – INFONEEDLE may disclose Personal Data about you to public authorities, such as law enforcement if we believe in good faith that we are required to do so in order to comply with laws or regulations, a subpoena, a search warrant, a court or regulatory order, or another valid legal process. We may disclose Personal Data in special circumstances when we have reason to believe that disclosing Personal Data is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Use or other user agreement, or to protect the safety or security of our users, ENGAGEZ or the general public.
3. Sale of Business – We reserve the right to transfer Personal Data to a third-party such as a subsidiary, parent company, co-owner or cooperator of ENGAGEZ and/or INFONEEDLE, or a successor entity in the event of a sale, merger or other transfer of all or substantially all of our assets, provided that the third party agrees to adhere to the terms of this Privacy Policy and INFONEEDLE provides you with notice of the same.
4. Security & Data Integrity.

INFONEEDLE takes reasonable steps to prevent the loss, misuse, and unauthorized access, disclosure, alteration and destruction of Personal Data about you. In addition, INFONEEDLE takes appropriate security measures to safeguard Personal Data about you once we have received it. Despite these efforts to store Personal Data collected on and through ENGAGEZ and otherwise by us in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to Personal Data. We do not warrant or represent that Personal Data about you will be protected against, loss, misuse, or alteration by third parties.

7. Data Retention.

INFONEEDLE will not keep Personal Data longer than is necessary for the purpose or purposes for which they were collected. INFONEEDLE will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. INFONEEDLE retains most Personal Data for up to five (5) years from the date it is no longer used and may retain some personal data for a longer period, to comply with our legal obligations, in relation to that Personal Data.

8. Your California Privacy Rights.

California Civil Code Section 1798.83 permits users that are residents of California to request certain information regarding INFONEEDLE’s disclosures of Personal Data to third parties for such third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please email INFONEEDLE at [email protected].

The California Online Privacy Protection Act (“CalOPPA”) requires INFONEEDLE to disclose how it responds to Do Not Track Signals in your web browser. INFONEEDLE does not interpret or respond to Do Not Track Signals. You may set your web browser to not accept new cookies or disable cookies altogether. Please note that doing so may hinder your experience on ENGAGEZ. Please see the Help section of your browser for instructions on managing security preferences.

9. Children’s Privacy.

ENGAGEZ is not directed to children younger than thirteen (13) years of age. We do not intend to collect Personal Data from children under 13. If you are under 13, please do not use ENGAGEZ and do not send any information about yourself to us.

10. International Transfers of Personal Data.

Some elements of ENGAGEZ and/or our products and services may be hosted on servers located in countries outside the United States. The laws applicable to the protection of Personal Data in such countries may be different from those applicable in your home country. In particular, if you are located within the European Union (the “EU”)/European Economic Area (the “EEA”) or Switzerland, please note that Personal Data collected by us may be transferred outside those countries. By using ENGAGEZ or our products or services, you consent to Personal Data about you being transferred outside your own country and, where applicable, outside the EU, EEA or Switzerland.

11. Changes to the Policy.

From time to time we may change this Policy with or without prior notice to you. You can tell when changes have been made to the Policy by referring to the “Last Updated” legend on top of this page. Please review this Policy regularly to ensure that you are aware of any changes. If we materially change the ways in which we use and disclose Personal Data, we will post a notice on ENGAGEZ and send an e-mail to our registered users. Your continued use of ENGAGEZ and/or our products and services following any changes to this Policy constitutes your acceptance of any such changes made.

12. Contacting Us.

Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to the INFONEEDLE administrative team at:

INFONEEDLE, INC
5575 Country Club Drive, Oakland, CA 94618
Phone: (415) 962-3708
Email: [email protected].com

We seek to promptly respond to and resolve any questions or concerns you may have.