Privacy Policy

Last Modified: December 14, 2020

1. Introduction
   ‍Seeen, Inc. (“Seeen”) is dedicated to protecting your personal information and informing you about how we use your personal information. This privacy policy applies to your use of the Seeen Services and Platform (as defined by the Subscriber Agreement and Terms of Use). This Privacy Policy should be read in conjunction with the Subscriber Agreement and Terms of Use and is integrated into the Subscriber Agreement and Terms of Use. All capitalized proper nouns not defined in this Privacy Policy will have the same definitions and meanings as defined by the Subscriber Agreement and Terms of Use. Please review this Privacy Policy periodically as we may revise it from time to time. If you do not agree with or accept our Privacy Policy in its entirety, you must not access or use the Platform. If you use the Platform following a change to the terms of this Privacy Policy you agree to accept the revised policies.
2. Information Collected
   ‍At Seeen, we collect personally identifiable information (“PII”) and non-personally identifiable (“Non-PII”) information from you. Personally identifiable information is information that can be used to identify you personally. Non-personally identifiable information is information that must be combined with other information to identify you personally.
   PII Collected
   ‍You will not be required to provide us any information when you visit our Platform. However, in order to access or use some portions of the Platform, we may collect PII such as username, payment details, log in information, name, address, business information. We may also collect your relevant payment or credit card information if you wish to pay for any services offered via the Platform. Please be aware that all payment information shall be stored and processed by our third party payment processors.
   Non-PII Collected
   ‍Whenever you use our website, we may collect Non-PII from you, such as your IP address, zip code, browsing history, search history, and registration history, interactions with the Platform, usage information, location, referring URL, browser, operating system, data usage, data transferred, and Internet service provider.
3. Use of Your Information
   ‍Some of your information will be visible to other users of the Platform to facilitate communication. We will never sell your information without your permission; however you agree that we may use your information in the following ways:
   - To provide any services offered and to operate Seeen Platform.
   - To enhance or improve our users’ experiences.
   - To to contact you via email or other electronic communications where you have an inquiry.
   - To notify you of additional Seeen services and updates.
   - To process your transactions.
   - To share your information with third party partners or third parties hired by us to perform functions and provide services to us subject to the obligations consistent with this Privacy Policy
4. Anonymized Data
   ‍Please be aware that we me may collect and aggregate personally identifiable information from our Platform and may anonymize that information for our own research or internal purposes. Once such data has been anonymized, it cannot be traced back to you, the user.
5. Accessing and Editing Your Information
   ‍You will be able to access any information contained in your account through our Platform. You may edit that information by changing the information listed in your account. If you have any questions or wish to review, change, or access any of your information collected by us, please contact us at support@seeen.com. After you have cancelled your account please be aware that we may keep inaccessible copies of your PII and non-PII subject to our data retention policies.
6. Cookies and Tracking
   ‍We use cookies for to understand how you use our Platform. Additionally, some third party cookies integrated into our Platform may track your usage information and interactions with the Platform. If you disable cookies from your web browser some portions of our Platform may not work.
7. Third Party Access to Your Information
   ‍Although you are entering into an agreement with Seeen to disclose your information to us, we do use third party individuals and organizations to assist us, including contractors, web hosts, and others to allow you to access the Platform. Throughout the course of our provision of our services to you, we may delegate our authority to collect, access, use, and disseminate your information. It is therefore necessary that you grant the third parties we may use in the course of our business the same rights that you afford us under this Privacy Policy. For this reason, you hereby agree that for every authorization which you grant to us in this Privacy Policy, you also grant to any third party that we may hire, contract, or otherwise retain the services of for the purpose of operating, maintaining, repairing, or otherwise improving or preserving our website or its underlying files or systems. You agree not to hold us liable for the actions of any of these third parties, even if we would normally be held vicariously liable for their actions, and that you must take legal action against them directly should they commit any tort or other actionable wrong against you.
8. Law Enforcement
   ‍You agree that we may disclose your information to authorities if compelled to by a court order. Additionally, you agree that we may disclose your information if we reasonably believe that you have violated US laws, the terms of our Subscriber Agreement and Terms of Use or our Privacy Policy, or if we believe that a third party is at risk of bodily or economic harm. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you and release your information without receiving any request to third parties where we believe that it is proper to do so for legal reasons, where your actions violate any law of the United States or any other country having jurisdiction over us, our Platform, or our Subscriber Agreement and Terms of Use. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants. We may release your information under the conditions listed in this paragraph whether it is to individuals or entities and to any state or federal authorities, as required.
9. Opt Out of Commercial, Non-Commercial Communications and Do Not Track
   ‍If you decide to provide us with your contact information, you agree that we may send you communications via text and emails. However, you may unsubscribe from certain communications by notifying Seeen that you no longer wish to receive these communications, we will endeavour to promptly remove you from our once we have received that request. We currently do not offer functionality for you to opt out through “do not track” listings. If you wish to opt out of certain communications or information collection, please contact us at support@seeen.com.
10. Third Parties
    ‍Seeen or other users may post links to third party websites on Platform, which may include information that we have no control over. When accessing a third party site through our Platform, you acknowledge that you are aware that these third party websites are not screened for privacy or security issues by us, and you release us from any liability for the conduct of these third party websites. Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, does not create rights enforceable by third parties. Seeen bears no responsibility for the information collected or used by any advertiser or third party website. You must review their policies to understand how their information collection practices work.
11. Security Measures
    ‍We make reasonable attempts to protect your information by using physical and electronic safeguards including encryption. However, as this is the Internet, we can make no guarantees as to the security or privacy of your information. For this reason, we recommend that you use anti-virus software, routine credit checks, firewalls, and other precautions to protect yourself from security and privacy threats.
12. Your California Privacy Rights
    ‍Seeen permits residents of the State of California to use its Platform, and complies with the California Business and Professions Code §§ 22575-22579. If you are a California resident you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes. Various provisions throughout this Privacy Policy address requirements of the Californian privacy statutes. Although we do not disseminate your information to third parties without permission, you must presume that we collect electronic information from all visitors. You may contact us at support@seeen.com with any questions.
13. Age Compliance
    ‍We intend to fully comply with American and international laws respecting children’s privacy including COPPA. Therefore, we do not collect or process any information for any persons under the age of 18. If you are under 18 and using our Platform, please stop immediately and do not submit any information to us. In the event that we have inadvertently collected any information from users under the age of 18 please contact us immediately.
14. International Transfer
    ‍Your information may be transferred to - and maintained on - computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. PII and Non-PII that is submitted to Seeen will be collected, processed, stored, disclosed and disposed of in accordance with applicable U.S. law and this policy. If you are a non-U.S. member, you acknowledge and agree that Seeen may collect and use your Information and disclose it to other entities outside your resident jurisdiction. In addition, such information may be stored on servers located outside your resident jurisdiction. U.S. law may not provide the degree of protection for information that is available in other countries.
15. Merger and Acquisition
    ‍In the event that Seeen is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. Please be aware that once the information is transferred your privacy rights may change.
16. Amendments
    ‍Like our Subscriber Agreement and Terms of Use, we may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will modify the date listed on this Privacy Policy or we may contact you. You must agree to the amendments as a condition of your continued use of our Platform. If you do not agree, you must immediately cease using our Platform and notify us of your refusal to agree by e-mailing us at support@seeen.com.
17. Privacy Notice for European Citizens
    ‍We respect the rights of persons living within the European Economic Community (EEC) and the rights afforded to them under the General Data Protection Regulation (GDPR), the sections 17-23 are referred to as our Privacy Notice and address additional privileges that EEC users may have under our Privacy Policy. This Privacy Notice explains how we shall assist our users who live within the EEC.Legal RightsYour Rights Under the GDPRThe right to be informedSeeen wishes to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data.The right to accessYou have the right to access your information at any time.The right to rectificationIf the information Seeen holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data.The right to erasureSometimes called ‘the right to be forgotten’. You have the right to request that Seeen to erase all your PII.The right to restrict processingYou have the right to ask Seeen to restrict how we process your data. This means we are permitted to store the data but not further process it. We will only keep enough data to ensure that we can accommodate any additional requests.The right to data portabilitySeeen must allow you to port and reuse your PII for your own purposes across different platforms. This right only applies to PII that you have provided to us as a data controller.The right to objectYou have the right to object to Seeen processing your data even if our processing is due to legitimate purposes as described in our Privacy NoticeThe right to withdraw consentIf you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and Seeen must stop processing your data.If you wish to exercise any of these rights or have questions about any of these rights please contact us at the information listed below.
18. Legitimate Purposes for Collecting Your PII
    ‍For the purposes of this Privacy Notice “personal data” as defined under the GDPR shall mean PII and Non-PII as defined in this Privacy Policy. The following are the specific legitimate purposes that we may use your personal data for:
    - Contract Administration - We may use your personal data to (1) negotiate, execute, renew and/or manage a contract with you; and/or (2) communicate with you in respect of the above (including sending (legal) notifications). (Performance of Contract)
    - Access and Communications to Our Platform – (1) interact with you through our Platform; (2) communicate with you regarding updates or in response to inquiries; and/or (3) manage and respond to your questions or comments (e.g. technical, commercial or administrative) or requests for maintenance and support. (Legitimate Interest)
    - Use of the Platform - We may use your personal data to (1) enable you to enjoy the use of, and easily navigate the Platform; (2) to understand how our Platform functions with you; and (3) to share with third parties we hire to maintain our Platform (Legitimate Interest)
    - Direct Marketing - We may use your personal data to contact you for additional products and services that you have expressed interest in. (Consent)
    - Training and Improvements - We may use your PII to (1) train our employees or contractors to allow for a better Platform experience; and/or (2) improve the Platform. (Legitimate Interest)
    - Please be aware that all legitimate purposes will be taken with minimal amounts of additional processing. Aside from the purposes listed, we may share your information where investigations or a legal dispute has occurred in accordance with our Privacy Policy (Legal Obligation).
19. Basis for Data Processing
    ‍Your personal data is processed by Seeen manually and/or using our Platform tools and third party providers as described in this Notice. Seeen shall process such personal data for specific purposes and only where there is a specific legal basis for doing as described above in Section 18.
20. Retention of Personal Information
    ‍Seeen will only retain your personal data for as long as required and proportionate to the use of your personal data. We will keep your personal data:
    - For any legally required duration.
    - Upon your request to eliminate, delete, or modify any of your personal data stored with us, we will honor such legitimate request.
    - Until we no longer have a valid reason to keep or use your personal data.
    - Where you have requested modification or deletion of your personal data, we may keep just enough of your personal information to ensure that we comply with your requests not use your personal information or comply with your right to erasure subject to any legal obligations or legitimate interests. If you require additional details regarding the retention of your personal data please contact us.
21. Security and Transfer of Personal Data Outside of the EEC
    ‍Your personal data is subject to the security provisions found within this Privacy Policy and the security measures we take are in line with industry standards. When you submit personal data to us it may be transferred and stored in the United States. Seeen shall ensure that your personal data shall have an adequate level of protection and that your information will be accessible as stated under the Privacy Notice.
22. Sharing of Data with Third Parties
    ‍We may disclose your personal information to a third party as described below subject to the legitimate purpose as specified within the Privacy Notice. We have entered into agreements (including but not limited to Data Protection Agreements) with all third parties that we disclose your personal information to and they are prohibited from selling such personal information. We share your personal data with the following third parties:
    Data Processor Purpose of Sharing Privacy Policy
    Google Use of the Platform; Training and Improvements; Analytics https://policies.google.com/privacy
    All Data Processors have entered into binding agreements with us that respect your rights under the GDPR. We use cookies via Google that are more fully described within their Privacy Policy
23. Data Controller Information
    ‍If you are an EEC resident and you have any questions regarding your rights under this Notice or wish to exercise any rights as enumerated under the GDPR, please contact us at: support@seeen.com or
    Seeen, Inc. – Data Privacy Officer
    199 Whitney Ave
    New Haven, Connecticut 06511
    United States of America.
    

Please label any email communications with the title “GDPR Request”.