Your Data: We do not and will not disclose or sell your data – period.
CALIFORNIA AND EUROPEAN CONSUMERS: DO NOT SELL MY PERSONAL INFORMATION. Ethos does not sell data to third parties, but if you would like to specifically opt out, or to exercise the other rights provided by the California Consumer Privacy Act or by the EU General Data Protection Regulation (GDPR) you or your representative can mail us at please contact us at email@example.com or via mail Ethos Corporation, Craigmuir Chambers PO Box 71, Road Town TORTOLA VG1110
1. WHAT IS A COOKIE? – Cookies are small text files that are sent to and stored on your computer or on your mobile device from our servers. They are widely used in order to make websites and cloud-based services work in a better, more efficient way. For example, they can recognize you and remember important information that will make your use of a website or cloud-based service more convenient (e.g., by allowing you to enter a password less frequently or remembering your user preferences). Taken alone, cookies do not personally identify you – rather, they merely recognize your Web browser. Unless you choose to identify yourself to Ethos by filling out a web form or you have previously identified yourself to us, you remain anonymous.
- Strictly Necessary Cookies – Some cookies are essential to the operation of our Sites. They are used to facilitate our log-in process, authenticate users, and enable you to navigate the Sites and to use their features. They are also used by our customer service team for in product messaging and analytics. Without these cookies, we may not be able to provide certain products, services or features, and the Sites may not perform as smoothly for you as we would like. Because strictly necessary cookies are essential to operate our products on the Sites, if you choose to use a product on our Sites, there is no option to opt out of these cookies.
- SendinBlue – SendinBlue provides email marketing, lead capture and web analytics to Ethos. SendInBlue captures visitor behavior and IP address information on our Sites. All web-browsers offer the option to refuse any cookie. If you refuse the SendInBlue cookies or delete them from your device, SendInBlue will not gather any personal information about you, you will need to re-enter certain information whenever you visit our Sites, and you’ll be prevented from customizing certain features on our Sites according to your preferences. SendInBlue may link the information they store in cookies to any personally identifiable information you choose to submit to Ethos while on our Sites. You may reject cookies and request to have data removed via form submission; you may also clear your browser’s cookies and website data to reject cookies from this third-party vendor. For more information, please visit the following pages: SendinBlue Cookies
- Google Analytics – Google Analytics is an ad management and ad serving technology. Google Analytics places cookies on the Sites so that we can record how many signups and leads originated from our marketing activity. For information on how to reject or delete this cookie, please visit: tools.google.com/dlpage/gaoptout
- Facebook – Facebook is used by the Sites for advertising, display ads and retargeting. For more information on Facebook’s cookie practices, please visit: www.facebook.com/policies/cookies/
- Instagram – Instagram is used by Sites to drive brand awareness, boost sales, and build and track audience engagement. For more information on Instagram’s cookies policy, visit: https://help.instagram.com/1896641480634370
- YouTube – YouTube is a video-sharing website that enables users to upload, view and share videos. The Ethos website contains embedded videos and/or directs users to the YouTube site. The videos shown on Ethos’s channel include those that include events, testimonials, and employees of Ethos and its related companies. Whenever a YouTube video is played or a still frame of a video is shown on our web site, a communication connection will be established with the corresponding YouTube server to exchange various data. These include the IP address of your computer, as well as previously stored cookies and information stored during previous contacts with YouTube. If no data has been stored before, the service will set an initial cookie on your computer. Whenever you contact a YouTube service, that service will also receive information about your YouTube account, in case you have one. When you interact with the video (e. g., by clicking the start, pause or stop button), details about these interactions will also be transmitted to the provider. You can terminate the data processing session by visiting a page that has no video content and deleting all cookies from your computer. Further information about YouTube’s data processing and data protection policies is available at https://policies.google.com/privacy
You can also learn more about controlling cookies in Section 4 below.
4. HOW YOU CAN CONTROL COOKIES ON OUR SITES – If you want to control the cookies that are placed on your computer, phone or other device, you could view cookies stored on your hard drive, choose whether or not to permit cookies to be set by default by changing browser settings as provided in this Section, or delete the cookies stored on your hard drive. Please be aware, however, that your decision to control cookies may affect your experience of our Sites – you may not be able to access all or parts of those Sites. Turning cookies off, for instance, will prevent you from registering for, signing in to, and using many of the services on our Sites.The main Web browsers allow you to change your cookie settings directly through their sites. These settings will typically be found in the ‘options’ or ‘preferences’ menu of your browser. In order to understand these settings, the following links may be helpful; otherwise you should use the ‘Help’ option in your browser for more details.
- Chrome: support.google.com/chrome/bin/answer.py
- Internet Explorer: support.microsoft.com/en-us/products/internet-explorer
- Safari: docs.info.apple.com/article.html
- Firefox: support.mozilla.org/en-US/kb/Cookies
For information on how to use the browser of your mobile device to amend cookie settings, you will need to refer to your mobile device manual.
The following third-party links contain additional information about cookies and other helpful information on your ability to control what cookies apply to you. Please note, however, that these links will take you to third party sites over which Ethos has no control:
- Offers comprehensive information on how to amend the settings of a wide variety of browsers, details on how to delete cookies from your computer, and more general information about cookies: www.allaboutcookies.org/manage-cookies/index.html
- Offers information about third-party cookies generated by advertisers and how to turn thee off by going to the International Advertising Bureau’s consumer site: www.youronlinechoices.com/uk
- Offers a comprehensive listing of opt-outs for advertising platforms; however, note that there are many more networks listed on this site than those used by Ethos and our Sites: www.networkadvertising.org
5. ‘DO NOT TRACK’ SIGNALS – Some Web browsers may be configured to send Do Not Track signals to websites, or users may use similar mechanisms, to indicate a user’s preference that certain web technologies not be used to track the user’s online activity. The Sites do not accept or process such Do Not Track signals or similar mechanisms.
Please review the entire policy to learn the types of Personal Data we gather, how we use that Personal Data, what Personal Data is disclosed and to what third parties, and how we safeguard your Personal Data.
2. WHAT INFORMATION IS BEING COLLECTED
- Personal Data – As you interact with and use our Sites, we may collect and use personal data from you. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include:
- Full name
- Company and company information
- Email address
- Information about your device: Manufacturer and model of your device; Internet Service Provider (“ISP”); Internet Protocol (“IP”) address (or other device identifier); browser type; and operating system
- Metadata: Location; cookies; access times and dates; referring/exit pages; clickstream data; pages of the Sites that you visit; the time spent on those pages or interacting with certain portions of the Sites; information you search for on the Sites.
- Sensitive Personal Data – We use the term “Sensitive Personal Data” to refer to a smaller subset of Personal Data which is considered more sensitive to the individual, such as: race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometrical information, physical or mental health information, medical insurance data, or sexual orientation. WE DO NOT COLLECT OR USE, AND WE DO NOT WANT YOU TO PROVIDE TO US, ANY SENSITIVE PERSONAL DATA. YOU ARE RESPONSIBLE FOR NOT SUBMITTING SENSITIVE PERSONAL DATA, THEREFORE, WE CONSIDER ALL DATA SUBMITTED TO OUR SITES NOT SENSITIVE.
3. HOW INFORMATION IS BEING COLLECTED – We obtain information about you from a variety of sources, including you, your interaction with our Sites, and third parties. Such information may include your name, postal address, e-mail address, and telephone number, among other personally identifiable information.
- Information You Provide Us – If you use certain of our services or communicate with us (by phone, chat, email, web forms, social media or other means of communication), you may be required to provide us certain information and Personal Data, in the following ways:
- Information that you provide by filling in forms on our website. This includes information provided at the time of registering to use our services, subscribing to our services, posting material, requesting further services or applying for a job.
- We may also ask you for information when you report a problem with or have a question about our services.
- Records and copies of your correspondence (including e-mail addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our services.
- Your search queries on our website or through our services. If you do not provide us with Personal Data, your ability to use certain aspects of our products and services may be limited.
- Information Provided To Us By Our Customers – Because our products and services are intended to be accessed and used by multiple users of each of our customers, it is possible that we may receive information and Personal Data about you that was submitted to us by our customer (your employer). Further, due to the nature of our products and services, it is possible that our customer may provide to us, in the course of using our products and services, information and Personal Data about its own users and customers.
We require our customers to agree to not share such information with us; however, we cannot control what our customers disclose to us. If Personal Data pertaining to you as an individual has been submitted to us by one of our customers and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with our customer directly. Because our personnel have limited ability to access data our customers submit to our products and services, if you wish to make your request directly to us, please provide the name of the Ethos (or related company) customer who submitted your data to us. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.
- Information We Collect From Your Use Of Our Services And Other Interactions You Have With Our Sites – We may collect your usage information about how you use our services, including your access times, location, browser types and language, and Internet Protocol addresses. We may collect device-specific information when you access our services, including your hardware model, operating system and version, unique device identifiers, mobile network information, and information about the device’s interaction with our services.
- This type of information is collected automatically by our servers when you access our Sites or use our services. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve and to deliver better and more personalized services, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our services according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our services.
- The technologies we use for this automatic data collection may include:
- Web Beacons – Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Information We Collect From Your Use Of Our Services And/Or Third-Party Services – We may also collect information about you from your interaction with and use of certain functionalities on our Sites:
- Messaging – The Sites provides messaging to enable users to communicate with us. We may review communications using the Sites’ messaging for legitimate business purposes, including in the course of customer service investigations regarding user complaints.
- Public Forums – Please note that if you use any comment posting feature, or post any information available for viewing by other users, any of the information that you share will be visible to other users. The information that you make available can be read, used, and collected by other users to send you unsolicited messages outside of the Sites. We are not responsible for the manner in which the Personal Data that you decide to share in this way will be used by other users.
- Social Media – We operate and maintain networking pages on social media platforms such as Discord, Telegram, Facebook, Twitter, LinkedIn, Google+ and Instagram. We may, from time to time, import comments and posts from these third-party platforms to the Ethos Sites. If you post to any of our networking pages on third-party social media platforms, you are providing information to the public and do so at your own risk. Further, we may use these postings on our Sites without notice or compensation to you. Please visit the privacy policies of any third-party social media platforms before posting to our pages there.
4. OUR LEGAL BASIS FOR COLLECTING PERSONAL DATA – Whenever we collect Personal Data from you, we may do so on the following legal bases:
- Your consent to such collection and use;
- Out of necessity for the performance of a contract between us and you, such as your agreement to use our services or our products;
- Our legitimate educational or business interest, including but not limited to the following circumstances where collecting / using Personal Data is necessary for:
- Product development and enhancement – where the processing enables us to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our customers, and to better understand how people interact with our Sites;
- Communications, marketing and intelligence – including processing data for direct marketing purposes (subject to your right to opt out as provided in Section 10 below) and to determine the effectiveness of our promotional campaigns and advertising;
- Fraud detection and prevention (crime prevention);
- Industry watch-lists and industry self-regulatory schemes;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General corporate operations and due diligence; Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purpose.
- Compliance with our legal obligations.
5. HOW WE USE YOUR PERSONAL DATA – We will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. We will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current. This Section provides additional information on how we use your Personal Data.
We use information about you to provide, maintain, personalize and improve our services and to deliver the information and support your requests, including support, marketing and administrative messages.
We may use information we collect to send you news and information about our services and to communicate with you about products or services. You may opt out of receiving promotional emails or text messages from us by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.
We may also use information about you (i) to track and analyze trends and usage in connection with our services; (ii) to protect our rights or property; (iii) to compare information for accuracy; (iv) to verify your identity; (v) to investigate and prevent fraud or other illegal activities; and (vi) for any other purpose disclosed to you in connection with our services. Additionally, we use information that we collect about you or that you provide to us, including any Personal Data:
- To provide you with information, products or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To carry out our obligations and enforce our rights arising from any contracts.
- To notify you about changes to our services or any products or services we offer or provide though them.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences.
We may use third-party service providers to process and store Personal Data in the United States and other countries. See Section 13 below for more information on our policies regarding international transfer of your Personal Data.
We may combine Personal Data about you that we have collected from different sources, for example, by combining publicly available information from various sources (e.g., LinkedIn and others) to help analyze sales opportunities.
6. HOW AND WITH WHOM WE SHARE YOUR PERSONAL DATA
Our policy is not to share the Personal Data we collect with third parties other than as specified below, or unless a user expressly consents to our sharing of certain information with a specified third party.
We will never share any Sensitive Personal Data with any other third party unless you have explicitly consented to such disclosure.
- With Your Consent – We may share Personal Data about you for any lawful purpose to which you have expressly consented or directed, or to fulfill the purpose for which you provided the Personal Data to us.
- To Our Business Partners And Vendors – We work closely with certain business partners and vendors and we may provide Personal Data to our business partners and vendors so that they can offer or provide services to you. For example, we may provide Personal Data to our business partners or other trusted entities for the purpose of providing you with information on goods or services we believe will be of interest to you. We may also employ third-party companies and individuals for any of the following: to facilitate the Sites; to provide the Sites or portions of the Sites on our behalf; to perform related services, including without limitation, maintenance services, database management, fulfillment, web analytics, and improvement of the features or functionality; or to assist us in analyzing how the Sites is being used. It is our policy to only share Personal Data with contractors, service providers and other third parties who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information. Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Sites.
- Compliance With Law And Protection Of Ethos And Others – We may release Personal Data when we believe, in our sole discretion, that release is appropriate:
- To comply with any court order, subpoena, law or legal process, including to respond to any government or regulatory request.
- To enforce agreements we may have with you.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers or others.
- To prevent activity that we believe, in our sole discretion, may be or may become illegal, unethical, or legally actionable (including exchanging Personal Data with other companies and organizations for fraud protection) such as money laundering or other illicit activities.
- Business Transfers – As we continue to develop our business, we may buy, sell, or share assets in connection with, for example, a merger, acquisition, reorganization, sale of assets, or bankruptcy. In such transactions, Personal Data about our users is often a transferred business asset. In the event that Ethos itself or substantially all of our assets are acquired, Personal Data about our users may be one of the transferred assets.
- Aggregate Site Use Information – We may release aggregate and anonymized / pseudonymized Personal Data to advertisers and other third parties in order to promote or describe use of the Sites.
7. YOUR FAILURE TO PROVIDE PERSONAL DATA – Your provision of Personal Data is required in order to use certain parts of our services and our products. If you fail to provide such Personal Data, you may not be able to access and use our services and/or our products, or parts of our services and/or our products.
8. OUR RETENTION OF YOUR PERSONAL DATA – We may retain your Personal Data for a period of time consistent with the original purpose of collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of our products and services and for a reasonable period of time afterward. If you are a customer, we may delete your Personal Data from our systems within sixty (60) days after termination of your agreement with us. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
9. YOUR DATA PROTECTION RIGHTS (EUROPEAN ECONOMIC AREA, CALIFORNIA CONSUMERS) – In some regions, such as the European Economic Area (“EEA”) and the State of California, you may have certain rights in relation to your personal information, including the right to access, correct, update, or request deletion of your personal information. Ethos takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. If you want to contact us directly about accessing, correcting, updating, or deleting your personal information, or altering your data or marketing preferences, you can do so at any time by contacting as provided in the Contact Us section. We will consider your request in accordance with applicable laws.
Craigmuir Chambers PO Box 71
Road Town TORTOLA VG1110
You can object to processing of your personal information, ask us to restrict processing of your personal information, request portability of your personal information, or restriction on the sale of personal information. Again, you can exercise these rights by contacting us at support@Ethos.io
You may also complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA and Switzerland are available here.
Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
We may ask you to verify your identity in order to help us respond efficiently to your request.
CALIFORNIA CONSUMERS: DO NOT SELL MY PERSONAL DATA – Ethos does not sell data to third parties, but if you would like to specifically opt out, or to exercise the other rights provided by the California Consumer Privacy Act, you or your representative can write to us at Ethos Corporation, Craigmuir Chambers PO Box 71, Road Town TORTOLA VG1110
10. CHANGING OR DELETING YOUR INFORMATION – You may update or correct information about yourself by emailing us at support@Ethos.io If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.
We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.
12. INTERNATIONAL TRANSFER – We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data. If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards to ensure that your Personal Data is protected. When necessary under applicable laws, we require our third-party service providers to agree to terms and conditions addressing the data privacy, data security, adequate data protection and transfer of Personal Data, and containing the standard contractual clauses authorized by the Commission Decision of 5 February 2010 under Directive 95/46/EC of the European Parliament and of the Council.
13. SECURITY – We are very concerned with safeguarding your information. We employ administrative and electronic measures designed to protect your information from unauthorized access. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we use commercially reasonable security measures such as encryption, 2FA and protocol secure (HTTPS) to protect Personal Data.
Please note that no security system is impenetrable. Accordingly, we do not guarantee the security of our databases, nor that information you supply won’t be intercepted while being transmitted to us over the Internet or other network. Any information you transmit to us, you do at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on or within our services. Where we have given you (or where you have chosen) a password for access to certain parts of our services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting through the Sites in the most expedient time possible and without unreasonable delay, as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
14. “DO NOT TRACK” SIGNALS – Some Web browsers may be configured to send Do Not Track signals to websites, or users may use similar mechanisms, to indicate a user’s preference that certain web technologies not be used to track the user’s online activity. The Sites do not accept or process such Do Not Track signals or similar mechanisms.
15. CHILDREN’S PRIVACY AND THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) – While we operate under the laws of the British Virgin Islands, we are committed to protecting the privacy of children and this includes respecting the provisions of The Children’s Online Privacy Protection Act (COPPA). In general, no person under the age of 18 may use the Ethos services. If we identify any person under the age of 18 we will terminate services.
The Children’s Online Privacy Protection Act (COPPA) was passed to give parents increased control over what information is collected from their children online and how such information is used. The law applies to websites and services directed to, and which knowingly collect information from, children under the age of 13. Ethos websites and online services are not directed to children under the age of 13, nor is information knowingly collected from them.
For additional information on COPPA protections, link to the Federal Trade Commission’s website at http://www.onguardonline.gov/articles/0031-kids-privacy
Information Collected Automatically
We automatically collect personal information when you or your child access and use our Services, including:
- Device and network identifiers such as IP address, mobile advertising ID, media access control (MAC) address, and identifiers associated with browser cookies, web beacons and similar technologies we deploy on the Services.
Internet or other electronic network activity information, such as your Internet service provider (ISP), browser type and operating system version, language settings, access times, pages viewed, the routes by which you access the Services, and your use of any hyperlinks available within the Services.
16. RIGHT TO REFUSE – Ethos reserves the right to not send gated materials requested by users of the Sites by submitting online forms, in order to protect company data or IP.
Policy last modified Oct 15, 2022