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Privacy Policy

Levelpath Privacy Policy

Last Updated: April 1, 2023

This Privacy Policy is designed to help you understand how Levelpath, Inc. (“Levelpath,”  “we,” “us,” or “our”) collects, uses, and shares your personal information, and to help you understand and exercise your privacy rights. 

1. Scope and updates to this privacy policy

This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called the “Services.” 

An Important Note: This Privacy Policy does not apply to any of the personal information that we process on behalf of our customers and their suppliers through their use of our Services (“Customer and Supplier Data”). Levelpath acts as processor with respect to Customer and Supplier Data. Our customers’ and their suppliers’ respective privacy policies govern their collection and use of Customer and Supplier Data. Our processing of Customer and Supplier Data is governed by the contracts that we have in place with our customers or their suppliers, not this Privacy Policy. Any questions or requests relating to Customer and Supplier Data should be directed to our customers or their suppliers

Levelpath acts as controller with respect to the personal information that we collect when you create an account and through our website as well as the personal information we collect from our employees and job applicants under this Privacy Policy.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

2. Personal information we collect

A. Personal Information You Provide to Us Directly

 

We may collect personal information that you provide to us.

 

  • Account Information. We may collect personal information in connection with the creation or administration of your account, such as your name, email address, phone number, address, and any other information that you provide to us or that we otherwise collect.

  • Purchase and Billing Information. We may collect personal information and details associated with your purchases on our Services, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details)
     

  • Transactional Information. We may collect personal information such as information relating to or needed to complete your orders on or through the Services, including order numbers and transaction history. 
     

  • Supplier Information. We may collect personal information from suppliers whose services are managed through our Services such as suppliers’ names, email addresses, phone numbers, business addresses, tax information and any other information that suppliers provide to us. 
     

  • ​User-Generated Content. We may collect personal information when you submit content through our Services, such as comments, chat messages, uploaded documents, and other content or information that you generate, transmit or otherwise make available on the Services, as well as associated metadata. 
     

  • Information Related to Your Communications with Us. We may collect personal information, such as your name, email address, phone number, and/or mailing address when you request information about Levelpath or our Services, register for our newsletter, request support, or otherwise communicate with us.
     

  • ​Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
     

  • Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. 
     

  • ​Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we may offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
     

  • ​Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events. 
     

  • Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities. 
     

  • Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us. 

B. Personal Information Collected Automatically 

 

We may collect personal information automatically when you use our Services.

 

  • Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
     

    • Crash Reports. If you provide crash reports, we may collect personal information related to such crash reports, including detailed diagnostic information about your device and the activities that led to the crash.
       

  • Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services. 
     

    • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
       

    • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

      Our uses of these Technologies fall into the following general categories: 
       

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
     

  • ​Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
     

  • ​Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
     

  • ​Advertising-or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties. 

    See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
     

  • Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics providers include:
     

    • ​​Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
       

    • LinkedIn Analytics. For more information about how LinkedIn uses your personal information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.
       

  • Social Media Platforms. Our Services may contain social media buttons, such as LinkedIn, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect personal information such as your IP address and which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

​C. Personal Information Collected from Other Sources

 

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations.  For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings. 

3. How we use your personal information

We use your personal information for a variety of business purposes and legal bases, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

If your personal information is subject to EU or UK General Data Protection Regulation, our processing of your personal information may be supported by one of the following lawful bases: 

  • Performance of a Contract. Levelpath may process your personal information to carry out our contract with you or to take steps at your request prior to entering into a contract. For a detailed list of uses for performance of contract, see Section 3(A).
     

  • Legitimate Interest. Levelpath may process your personal information to further our legitimate interests, but only where our interests are not overridden by your interests or fundamental rights and freedoms. For a detailed list of our legitimate interests, see Section 3(B). 
     

  • Compliance with Legal Obligations. Levelpath may process your personal information to comply with our legal obligations as detailed in Section 4(B).
     

  • Consent. In some cases, Levelpath may also rely on your consent to process your personal information for a specific purpose.

 

A. Provide Our Services

 

We use your personal information to fulfill our contract with you and provide our Services, such as:

 

  • Managing your information and accounts;

  • Providing access to certain areas, functionalities, and features of our Services;

  • Answering requests for customer or technical support; 

  • Communicating with you about your account, activities on our Services, and policy changes;

  • Processing your financial information and other payment methods for products or Services purchased;

  • Processing applications if you apply for a job we post on our Services; and

  • Allowing you to register for events.
     

B. Administrative Purposes

We have a legitimate interest in using your personal information for various administrative purposes, such as:

 

  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

  • Measuring interest and engagement in our Services; 

  • Short-term, transient use, such as contextual customization of ads;

  • Improving, upgrading, or enhancing our Services; 

  • Developing new products and services;

  • Ensuring internal quality control and safety;

  • Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;

  • Debugging to identify and repair errors with our Services;

  • Auditing relating to interactions, transactions, and other compliance activities;

  • Sharing personal information with third parties as needed to provide the Services;

  • Enforcing our agreements and policies; and

  • Carrying out activities that are required to comply with our legal obligations.

 

C. Marketing and Advertising our Products and Services

 

We have a legitimate interest in using your personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we may market to you include email campaigns, custom audiences advertising, and “personalized advertising” or “targeted advertising,” including through cross-device tracking.
 

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below. 

 

D. With Your Consent

 

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

 

E. Creating De-Identified and/or Aggregated Information.

 

We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about how you use the Services, information about the device from which you access our Services, or other analyses we create. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by applicable laws or required to comply with. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.

4. How we disclose your personal information

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. 

 

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below. 

  • Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.

 

  • Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

 

  • Affiliates. We may share your personal information with our corporate affiliates. 

 

  • Other Users or Third Parties You Share or Interact With. As described above in “Personal Information We Collect,” our Services may allow you to share personal information or interact with other users and third parties (including individuals and third parties who do not use our Services and the general public). 

 

  • Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “personalized advertising,” or “targeted advertising.” 

 

  • APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
     

B. Disclosures to Protect Us or Others

 

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

 

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

 

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. Your privacy and choices

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below. 

 

  • Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy). 

 

  • Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.

 

  • Phone Calls. If you receive an unwanted marketing phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or by otherwise contacting us as set forth in “Contact Us” below.

 

  • “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

 

  • Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for AndroidiOS, and others.

    The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiativethe Digital Advertising Alliancethe European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.  

    Please note you must separately opt out in each browser and on each device. 

 

Your Privacy Rights. In accordance with applicable laws, you may have the right to:

 

  • Confirm Whether We Are Processing Your Personal Information (the right to know);

  • Request Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);

  • Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

  • Request Deletion of your personal information; 

  • Request Restriction of or Object to our processing of your personal information where the processing of your personal information is based on our legitimate interest or for direct marketing purposes; 

  • Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal; and

  • Contact Supervisory Authority. If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law. 


If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

6. International transfers of personal information

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.

 

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses

 

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below. 

7. Retention of personal information

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.  

 

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. Supplemental notice for Nevada residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at privacy@levelpath.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.

9. Children's information

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children.

 

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

10. Other provisions

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk. 

11. Contact us

Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

 

Levelpath, Inc. 

Attn: Legal

50 Fremont St. STE 2250

San Francisco, CA 94105

privacy@levelpath.com

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