Thank you for visiting eCairn Inc.’s (“eCairn”) Internet web site located at the URL: eCairn.com.This Privacy Policy details certain policies implemented throughout eCairn governing eCairn’s use of personally identifiable information about users of our Site and users of our services and hosted application accessible on the Site (collectively, “Services”). By clicking on “I Agree,” you agree to be bound by all of the terms and conditions of this Privacy Policy. If you do not agree to all of the terms and conditions, then do not click on “I Agree” or access the Site or use the Services on the Site.

Who are We:

We are eCairn Inc. (“we”, “us”, “our” or “eCairn”), a provider of “social listening”, “social selling” and market intelligence services, through our proprietary platform eCairn Conversation ™ and our web application eCairn Advocate App (sales)  and Dashboard app (sales management).To provide our Services, we crawl various sources on the Internet (e.g. websites, blogs, social networks), we collect and purchase publicly available information, including personal data. Then, we analyze, index such information and create new data (aggregated or computed).eCairn, working since 2007 in the Social Intelligence domain both in the US and Europe has developed a strong experience in privacy and the security of personal data. Our system combines processes, tools and vendor selection to ensure data security. As a SaaS company, we benefit from the high degree of security of Amazon (AWS) and Google (the companies hosting our data).

Privacy Policy Updates:

Due to the Internet’s rapidly evolving nature, eCairn may need to update this Privacy Policy from time to time. If so, eCairn will post our updated Privacy Policy on the Site located at the following URL: http://ecairn.com/privacy-policy  and post notice of the change and/or may communicate the changes by sending e-mail notices to registered users of the Site. eCairn encourages you to review this Privacy Policy regularly for any changes. Your continued use of the Site, Services, and/or continued provision of personally identifiable information to us will be subject to the terms of the then-current Privacy Policy. Information Collection and use you can generally visit our Site without revealing any personally identifiable information about yourself. However, in certain sections of this Site, through the log-in process or when you request an online demo, register for an account on the Site, contact us with questions or comments or request information, provide us with feedback, participate in surveys, questionnaires, or contests or subscribe to our blog, we may collect personally identifiable information from you such as your name, company name, email address, password, username and other contact information that you voluntarily transmit with your communication to us. You are required to provide your e-mail address and password when logging into the Site. Additionally, we may collect personally identifiable information about you that you provide to us when you contact us or that you voluntarily include in your feedback and/or e-mail, phone, or in-person communications with us. We also may collect the foregoing personally identifiable information about you from our third-party affiliate or partner companies and from marketing or advertising companies that provide us with such information as a part of their relationship with us. We also may collect information about you and your use of our Site and Services through your use of our Site and Services. We may use your personally identifiable information to register you to use our Services, contact you to deliver certain Services or information that you have requested, verify your authority to enter our Site, improve the content and general administration of the Site and our Services, provide you with notices regarding Services that you have purchased or may wish to purchase in the future, provide you with notices about other users of our Site and/or Services that you may wish to contact. In addition, if you subscribe to our blog, we will use your e-mail address to send you notifications of new posts to our blog.

Children’s Privacy:

eCairn recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. This Site is not intended for children under the age of 13. eCairn does not target this Site or its Services to children under 13. eCairn does not knowingly collect personally identifiable information from children under the age of 13. Aggregate InformationThe Site may utilize software that tracks the total number of visitors to our Site, the number of visitors to each page of our Site, browser type, IP addresses, Exte rnal Web Sites (defined below) linked to, and we may analyze this data for trends and statistics in the aggregate, but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such aggregate information to analyze trends, administer the Site, track users’ movement, and gather broad demographic information for aggregate use.

Disclosure:

We may provide your personally identifiable information to the vendors and service agencies that we may engage to assist us in providing our services. For example, we may provide your personally identifiable information to PayPal to process your payment. – NOTE: Confirm if any personally identifiable information of eCairn website users is passed to PayPal? We will also disclose your personally identifiable information (a) only if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of governmental authority, (b)to enforce the eCairn Terms of Use Agreement or to protect our rights or (c) to protect the safety of users of our Site and our Services. We may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which eCairn participates or to a purchaser or acquirer of all or substantially all of eCairn’s assets to which this Site relates. Links to Third-Party SitesThe Site may provide links to other Web sites or resources over which eCairn does not have control(“External Web Sites”). Such links do not constitute an endorsement by eCairn of those External Websites. You acknowledge that eCairn is providing these links to you only as a convenience, and further agree that eCairn is not responsible for the content of such External Web Sites. Your use of External Websites is subject to the terms of use and privacy policies located on the linked to External Web Sites.SecurityWe may employ procedural and technical measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction.eCairn may use firewalls, password protection, secure socket layer and encryption to help prevent unauthorized access to your personally identifiable information.

Updating, Correcting and/or Deleting Personally Identifiable Information

eCairn provides you with the ability to review and correct your user name and password that you have provided to us. If you wish to update or correct your user name and/or password, you may access your account online or submit a request to us by phone or email at: By e-mail: conversation@ecairn.comBy phone:(408) 560-9450

Processing of Personal Information 

Our computer systems are currently based in the United States, so your personal data will be processed by us in the U.S. where data protection and privacy regulations may not offer the same level of protection asin other parts of the world, such as the European Union. If you create a user account with our Web site as a visitor from outside the United States, by using our Web site you agree to this Privacy Policy and you consent to the transfer of all such information to the United States, which may not offer an equivalent level of protection of that required in the European Union or certain other countries, and to the processing of that information as described in this Privacy Policy.

European Union / GDPR

As part of the GDPR requirements, please find below our detailed activity & processes on personal data and the rights you can claim about your personal data. Here is the EU definition of personal data: https://gdpr-info.eu/art-4-gdpr/

Controller

eCairn is responsible for the protection of personal data that it collects from publicly available information and adds to its research database. As such, we are a controller under applicable data protection legislation for personal data which we obtain about you.

Personal data definition

Here is the EU definition of personal data: https://gdpr-info.eu/art-4-gdpr/

Data processed by eCairn?

eCairn processes four different types of personal data :

1. Employees and subcontractor data.

2. Clients and prospects data

3. Personal data from users of eCairn Conversation ™ app and eCairn Social Selling applications.

4. Influencers and “who’s who”/affluent profiles. Data purchased from data providers and indexed from the Internet using our proprietary software

The latter (#4) is clearly the area where eCairn has the most volume of personal data i.e we collect and index the data from influencers and “who’s who”.The personal data we index as part of #4 is public data that we obtain directly or indirectly from social media networks.eCairn is only indexing data that is voluntarily posted on the Internet with a public status and which has been prone to expressed consent regarding the use by third parties. This includes:

• name, username, pseudonym, or other identifier

• profile picture

• public content published using that name, username, pseudonym, or another identifier, including e.g. posts, comments, expressions, opinions, likes.

• other images or videos that publicly posted or interacted with;

• location, as provided to us by any third-party website, page, forum, a social network that shares such data with us, subject to your choices and preferences on such third-party website, page, forum, social network.

• information generally made available on a website, page, forum, social network we are authorized to crawl or that shares data with us.

eCairn never collects information that has a private status and is not able to access profiles or pages online and social networks, if the access has been restricted by the user.eCairn does not collect emails nor phone numbers. eCairn allows its clients to upload emails and phone numbers they have collected on their own. This information stays private to this specific client.eCairn does not collect or try to infer from the information we collect, any information that reveals the racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health condition,  negative financial status, and sexual orientation.eCairn does not collect data for people younger than 16 years old. eCairn uses personal data to the extent that the law allows us to do so. We will use your personal data where it is necessary to pursue our legitimate interests and your interests and fundamental rights do not override those interests.

How eCairn uses data?

Employees, Clients, Partners, Suppliers and Users:

(#1), (#2), (#3)eCairn uses data on Employees, clients, suppliers, partners and users to conduct normal business functions such as communication, support, payment, invoicing, sales. We use cookies to optimize the flow on our website. We also monitor and collect data about the use of our services by our users in order to improve them. We also collect information relative to the devices that you use to visit our website or use our application.

Influencers & Web Users (who’s who and affluent people)

(#4)For influencers and affluent people, eCairn uses the data to help our users discover, listen to, evaluate and manage their engagement with influential and affluent people.

• identify “key people” our clients should talk to/engage with/follow and help our clients being effective and relevant in engagement

• Infer information such as gender, age, the center of interest, profession, influence on key topics.

  eCairn only supports 1:1 engagement use cases and our solution does not include mass emailing nor advertising capabilities toward a large audience. The outcome of using eCairn’s service is either

• An intelligence report on an audience

• A more effective way of using social media one-to-one.

Typical use case: a B2B Tech client wants to identify the most influential people in cloud computing in the UK to talk to.  Analyzing public data on the internet- data that people explicitly post to reach a large audience -:

• eCairn builds a list of the best people for our client to talk to,

• eCairn provides a report on this audience (how many they are, what they talk about …)

• along with trending topics of the day/week.

• eCairn then highlights public posts from the audience that the user should be aware of and engage with.

How is this web public data indexed?

As part of its collection activity, eCairn uses automated indexing systems, also known as “crawlers”. Our crawlers are identifiable and site owners can opt to block them or contact us with more information. They can do so by contacting us directly or by filing an abuse report with AWS.  eCairn maintains a list of websites that have explicitly opted for not been crawled and we stop crawling web sites and remove the data within 48 hours after notification, Our data are stored at AWS data centers that are GDPR ready (https://aws.amazon.com/blogs/security/all-aws-services-gdpr-ready/).eCairn also purchases data from Social networks (Twitter).eCairn also purchases data from GDPR compliant vendors.

For what purpose do we use data?

We process data about  Web users, Influencers, Customers on the basis of our legitimate interest in providing our Services and improving our Services to our clients. We do our best to collect and process data that is of maximum accuracy and freshness. We implement “privacy by design” and don’t keep the data longer than necessary. We perform automatic deletion when to ensure this rule is enforced. As an example, although we could collect people physical address for research objective, we limit ourselves to collecting zip codes which do not enable to identify individual people

Your rights (as data subject)

Pursuant to applicable data protection and privacy laws, you have a number of rights that you may exercise upon personal data concerning you.  (see the document: https://gdpr-info.eu/chapter-3/)You can:

• The right of access to its data( Article 15 GDPR ) You can ask us if we hold any personal data about you.

• Right to object (Article 21 GDPR ) & Right to be forgotten ( Article 17 GDPR ):  Request access to the personal data concerning you that we hold and, as the case may be, request that we update, rectify or erase such personal data.

• Request that we refrain from using personal data concerning you in the future.

• If you reside within the European Union, you have the right to ask for a copy of your personal information. Please note that such a request is limited to the only personal information you provided us with and that we hold at that given time and subject to any relevant legal requirements and exemptions.

In respect of the above rights, in order to comply with legal requirements pertaining to privacy, we will verify your identity and may require that you provide additional information before we enforce your rights. We generally would deliver this information at no fee. We may charge a reasonable processing fee if the request is repetitive or excessive. Please note that we may be required by law to retain data, and therefore will not erase or rectify such data. For instance, we are required by the applicable law to retain certain data for accounting and financial compliance reasons.

Q&As

If you wish to obtain more information or to assert your rights on your personal data, you can contact us right now at : Email: conversation+privacy@ecairn.com  Attention: eCairn Data Protection Officer