Policies

ExpertVoice Privacy Policy

PRIVACY POLICY

Effective Date: May 20, 2020

This Privacy Policy describes how ExpertVoice, Inc. (“ExpertVoice,” “we,” “us,” “our”), a
company located and incorporated in the United States, collects, uses, and shares
information about you that is captured while you use ExpertVoice.com or ExpertVoice’s
mobile application (collectively, “sites”).

By using our sites, registering for our services, or by choosing to submit personal
information to ExpertVoice through the sites, you agree to the terms of this Privacy
Policy. You are not required to provide any personal information, but if you choose not
to, you may not be able to access certain information or areas of the sites. If you do not
agree with any terms of this Privacy Policy, please do not use the sites or submit any
personal information to ExpertVoice.

ExpertVoice is based in the United States, with servers located in the United States. By
using our sites, you consent to the collection, transfer, storage, processing, disclosure,
and other uses of your information in the United States as described in this Privacy
Policy to the extent permitted by applicable law

WHAT INFORMATION WE COLLECT

ALL USERS

When you visit our sites, we collect personal information about you. “Personal
Information” means information that identifies a particular individual including:

  • Real name, alias, unique personal identifier, online identifier, Internet Protocol
    address, or account name;
  • Education, employment, employment history or credit card number;
  • Commercial information including products or services purchased, obtained or
    considered, or other purchasing or consuming histories or tendencies;
  • Internet or other electronic network activity information regarding a consumer’s
    interaction with an Internet website; and
  • Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences,
    characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal Information also includes “personal data” as defined by the General Data
Protection Regulation (GDPR) and “personal information” as defined by the California
Consumer Privacy Act (CCPA). Personal Information is collected when you fill out
forms, communicate with us through our sites, or create an online profile. We may
collect Personal Information that you make publicly available, such as if you write a
product review or make a comment on another user’s content.

We may also collect certain information about your use of our sites such as information
about your computer, including your IP address, the type of browser you are using, and
your computer’s operating system. Except as otherwise explained in this Privacy Policy
or as may be prohibited by law, we may combine this information with your
Personal Information.

We may also collect certain information from your employer including name, email
address, and employment information (unique employee number, job title, job status,
retail location).

ONLINE PROFILE

When you create an online profile, you may choose to provide optional information such
as your employer, training modules completed, purchases you make, product reviews,
photographs, points earned, etc. Any information you provide on your profile is subject
to this Privacy Policy. Information you choose to upload or publish to a public area of
your profile will appear on the sites and may be viewed by other members and brands.
If you choose to include Personal Information in a public area of the sites, you consent
to the public disclosure of the Personal Information you choose to post. If you do not
wish to publish your Personal Information in this manner, please do not include it in
material you post to a public area of the sites. We provide you ways to control the public
sharing of your profile, generally, and data within your profile at the following link:
www.expertvoice.com/account

COOKIES AND OTHER TRACKING TECHNOLOGY

Our sites also use “cookies” (small data files stored on your computer) and other
tracking technologies to collect information about your visit to our sites. The cookies that
may be used by ExpertVoice fall into the two categories described below. These
descriptions can help you determine if and how you would like to interact with the sites.

  • Essential Cookies: These cookies are absolutely necessary for the sites to
    function properly and cannot be switched off in our systems. This category
    includes cookies that ensure the basic functionality and security of the sites.
    These cookies do not store Personal Information.
  • Non-Essential Cookies: These cookies may not be necessary for the sites to
    function and are used to collect Personal Information on users via analytics, ads,
    and other embedded content. These cookies often help us improve the
    experience of the website.

Users may opt out of non-essential cookies by going to www.expertvoice.com/account.
Once on the page, you will see a box labeled Cookies where you can toggle off NonEssential Cookies.

Our sites and services do not respond to browser “Do Not Track” signals.

The cookies and tracking technologies we use do not capture Personal Information. The
information that is captured about your visit may be used in a variety of ways, such as to
monitor and maintain information about your visits to our sites, to help us identify and
address problems, to improve our sites, to analyze web traffic trends, and to help
protect the security and integrity of our sites. You may set your browser not to accept
cookies or to notify you when you receive cookies, giving you the opportunity to decide
whether to accept cookies. If you do not accept cookies, you may still use our sites, but
your experience may be degraded. We may also use pixel tags (also known as “clear
gifs,” “Web beacons,” or “1-by-1gifs”) on our sites. These may be used in connection
with certain pages of our sites or with email messages to measure the effectiveness of
our communications and our marketing campaigns, to compile statistics about usage
and response rates, and to assist us in resolving issues that may arise on our sites.

Third-party vendors may collect Personal Information about your online activities over
time and across different websites when you use the sites.

Our sites use Google Analytics, a web analytics service provided by Google Inc.
(“Google”). On our behalf, Google will use the cookies to collect information to evaluate
your use of the sites, compile reports about activity on the sites, and to provide other
services related to the sites and Internet use. Learn more about Google Analytics and
your choices by visiting this website: https://tools.google.com/dlpage/gaoptout.
You can also learn more about online advertising cookies and your ability to opt-out of
certain online advertising cookies by visiting the following websites:
http://www.aboutads.info/choices or http://www.networkadvertising.org/choices. For
your mobile device, you can understand which third parties have currently enabled
cookies on your mobile device and how to opt-out of some of those cookies by
accessing the Network Advertising Initiative's website at
http://www.networkadvertising.org/mobile-choices from your mobile device. On your
mobile device you may also select “Limit Ad Tracking” (on iOS devices) or “Opt out of
Interest-Based Ads” (on Android). Even if you disable tracking, keep in mind that you
may still receive interest-based advertising, including from third parties with whom your
information had been previously disclosed and that you may still receive advertising
from third parties, though such advertising may not be based on your interests and
preferences.

HOW WE USE COLLECTED PERSONAL INFORMATION

We may use the Personal Information we collect for the following purposes:

  •  To respond to your inquiries and fulfill your requests;
  •  To send you important information regarding our sites, changes to our terms,
    conditions, and policies, and/or other administrative information;
  • To send you marketing communications that we believe may be of interest to
    you, if you have agreed to receive such messages;
  • To personalize your experience on our sites by presenting content tailored to
    you;
  •  To allow you to take and keep track of training;
  •  For our business purposes, such as data analysis, audits, developing new
    products, enhancing our sites, improving our services, identifying usage trends,
    furthering brand relationships, and determining the effectiveness of our
    promotional campaigns;
  • For risk control, to comply with laws and regulations, and to comply with other
    legal process and law enforcement requirements;
  • To use information about your activities on the sites to communicate your training
    progress to your employers and in some cases to offer you retail discounts; and
  • For other purposes which are disclosed to you and to which you consent.

We may also use information that we receive about you from your employer and data
providers who assist us in processing requests, maintaining our data, and optimizing
our services.


We may also use your Personal Information for business purposes such as:

  • Auditing related to a current interaction with the consumer and concurrent
    transactions, including, but not limited to, counting ad impressions to unique
    visitors, verifying positioning and quality of ad impressions, and auditing
    compliance with this specification and other standards;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent,
    or illegal activity, and prosecuting those responsible for that activity;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Short-term, transient use, provided that the personal information is not disclosed
    to another third party and is not used to build a profile about a consumer or
    otherwise alter an individual consumer’s experience outside the current
    interaction, including, but not limited to, the contextual customization of ads
    shown as part of the same interaction;
  • Performing services, including maintaining or servicing accounts, providing
    customer service, processing or fulfilling orders and transactions, verifying
    customer information, processing payments, providing financing, providing
    advertising or marketing services, providing analytic services, or providing similar
    services;
  • Undertaking internal research for technological development and demonstration;
  • Undertaking activities to verify or maintain the quality or safety of a service or
    device that is owned, manufactured, manufactured for, or controlled by us, and to
    improve, upgrade, or enhance the service or device that is owned, manufactured,
    manufactured for, or controlled by us;
  • For other legitimate purposes as permitted by law; and
  • Any commercial purposes, including any purpose to advance your commercial or
    economic interests, such as by inducing you to buy, rent, lease, join, subscribe
    to, provide, or exchange products, goods, property, information, or services, or
    enabling or effecting, directly or indirectly, a commercial transaction.

SHARING YOUR INFORMATION

We do not sell your Personal Information. We will not disclose your Personal
Information to third parties except as described in this Privacy Policy, to the extent
necessary to provide you with a requested service, or under any other circumstances
permitted by law. You agree that we may also disclose this information to third parties:
(1) when we have reason to believe that such disclosure is necessary to identify,
contact, or bring legal action against someone who may be causing injury to or
interference with (either intentionally or unintentionally) our rights or property, customers
or other users of our sites, or anyone else who could be harmed by such activities; (2)
to respond to judicial process and provide information to law enforcement agencies or in
connection with an investigation on matters related to public safety, as permitted by law,
or otherwise as required by law, such as to comply with a subpoena or similar legal
process; or (3) for any other legitimate business purpose not prohibited by law. Please
note that we may be required to release an individual’s Personal Information in
response to a legal inquiry from public authorities including to meet national security or
law enforcement requirements.

We may share information about your activity on the sites with brands, and in some
cases your employers. This includes sharing your product reviews with the brands and
in some instances the brands’ syndicated review network. We may transfer your
Personal Information to third party service providers that assist us with carrying out
these purposes. For example, we may use a data processing contractor to operate
computer systems on our behalf, for administrative, technical support, or other business
purposes as necessary to facilitate our transactions with you, analyze our data, conduct
analytics services, or to maintain and improve our services. Whenever any Personal
Information is transferred to such third party service provider, that party will be
contractually bound to use such Personal Information only to carry out the services we
have requested, to abide by our Privacy Policy, and to provide adequate protection for
the Personal Information.

If we are involved in a merger, acquisition, financing due diligence, reorganization,
bankruptcy, receivership, 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. We cannot control how such entities may use or disclose such
information. We may disclose your Personal Information for any other purpose with your
consent.

When ExpertVoice receives Personal Information under the EU–US Privacy Shield
Framework or the Swiss–U.S. Privacy Shield Framework (as explained in the Privacy
Shield section below) and then transfers the Personal Information to third party
services, we are liable for any processing of Personal Information by such third parties
that is inconsistent with the Privacy Shield Principles, unless we are not responsible for
the event giving rise to any alleged damage.

YOUR CHOICES FOR CONTROLLING YOUR
INFORMATION

CORRECTING OR CHANGING YOUR INFORMATION

We acknowledge the individual’s right to access their Personal Information. We are
concerned about the accuracy, currency, and completeness of the Personal Information
we collect and take appropriate steps to ensure that the information we have is accurate
and up to date. In addition to the options provided to you in this Privacy Policy, if you
wish to review, amend, correct, update, or delete Personal Information we have
collected about you online, or to opt out of receiving our marketing communications,
contact us at 1-866-376-4685, support@expertvoice.com or
https://www.expertvoice.com/contact.

California users, please see the California Privacy Rights section below to find out how
to exercise your rights. European users, please see the European Union section below
to find out how to exercise your rights.

You may also contact us by writing to:
ExpertVoice
Attn: Expert Success
9 Exchange Place, Suite 1000
Salt Lake City, Utah 84111

We will respond to your access request within any legally required time period. We
reserve the right not to allow access to your information if we believe in good faith that
such disclosure is prohibited by law or if the rights of another individual might be
violated.

You may cancel your registration to our sites and/or request the removal of your
Personal Information from our visitor records by sending an email to
support@expertvoice.com or visiting us at https://www.expertvoice.com/contact.

CALIFORNIA PRIVACY RIGHTS

Under the California Consumer Privacy Act (CCPA), California residents have the right
to:

  • Request that a business delete any personal information about the consumer
    which the business has collected from the consumer.
  • Request that a business that collects personal information about the consumer
    disclose to the consumer, free of charge, the following:

    • The categories of personal information the business has collected about
      the consumer in the preceding 12 months.
    • The categories of sources from which the personal information is
      collected.
    • The business or commercial purpose for which it collected or sold the
      personal information.
    • The categories of third parties with which the business shares personal
      information.
    • The specific pieces of personal information it has collected about that
      consumer.
  • Request that a business that sells the consumer’s personal information, or that
    discloses it for a business purpose disclose, free of charge, to the consumer:

    • The categories of personal information that the business sold in the
      preceding 12 months, and for each category identified, the categories of
      third parties to which it sold that particular category of personal
      information.
    • The categories of personal information that the business disclosed for a
      business purpose in the preceding 12 months, and for each category
      identified, the categories of third parties to whom it disclosed that
      particular category of personal information.
  • Direct a business that sells personal information about the consumer to third
    parties not to sell the consumer’s personal information.

We will not discriminate against you if you choose to exercise any of your rights as
described in this section.

HOW TO SUBMIT A REQUEST

You may submit a request under the CCPA through the following methods:

  • You may call us toll-free at 1-866-376-4685.
  • You may e-mail us at support@expertvoice.com.

To submit a request, we are required to verify your identity. Users will be required to
provide the primary email address listed on the account. A verification email will then be
sent to that email address in order to verify your identify. We may need to contact you to
confirm your request.

Consumers may use an authorized agent to submit their request. The authorized agent
must be registered with the California Secretary of State and be authorized to submit
requests on behalf of a consumer. If you are an authorized agent and a consumer has
given you written and signed permission to submit a request on his or her behalf, please
send a copy of your signed permission by the consumer to ExpertVoice. Failure to
submit proof of signed permission may result in ExpertVoice denying the consumer’s
request. ExpertVoice will require the consumer to verify his or her identity and directly
confirm with ExpertVoice that the consumer has provided you with permission to submit
the request.

EUROPEAN UNION

This section of our Privacy Policy provides certain required information to persons
located in the European Union (“EU”), a European Economic Area (“EAA”) member
state. Before ExpertVoice collects any Personal Information, you are entitled under the
General Data Protection Regulation (GDPR), to the information in this section of our
Privacy Policy.

LEGAL BASES FOR PROCESSING PERSONAL INFORMATION

ExpertVoice will only process your Personal Information when ExpertVoice has a lawful
basis for doing so. ExpertVoice will collect and process your Personal Information as
necessary for the performance of a contract to which you are a party or because
ExpertVoice has another legitimate interest in doing so relating to ExpertVoice’s
business purposes arising from your relationship with ExpertVoice. ExpertVoice may
also seek your prior consent or rely on some other lawful basis to process your
Personal Information.

RIGHTS OF USERS LOCATED IN THE EU

If you use our sites and are located in the EU or EAA you are entitled by law to access,
correct, amend, or delete Personal Information about you that we hold. A list of these
rights is below. Please note that these rights are not absolute and certain exemptions
may apply to specific requests that you may submit to us.

  •  The right to access. You have the right to ask us for copies of your Personal
    Information. When making a request, please provide an accurate description of
    the Personal Information to which you want access. We may charge a
    reasonable fee based on administrative cost.
  • The right to rectification. You have the right to ask us to rectify information you
    think is inaccurate. You also have the right to ask us to complete information you
    think is incomplete.
  • The right to erasure. You have the right to ask us to erase your Personal
    Information in certain circumstances, including your Personal Information must
    be erased to comply with a legal obligation under EU or member state law.
  • The right to restrict processing. You have the right to ask us to restrict the
    processing of your Personal Information in certain circumstances, including: (i)
    when the accuracy of the Personal Information is brought into question, or (ii)
    when we no longer need the Personal Information for the purposes of the
    processing but you require such Personal Information for the establishment,
    exercise, or defense of a legal claim.
  • The right to data portability. You have the right to ask that we transfer the
    Personal Information you gave us from one organization to another, or give it to
    you.
  • The right to lodge a complaint with the supervisory authority. If you believe
    your rights under the GDPR have been violated, the GDPR gives you the right to
    file a complaint with your supervisory authority. A list of supervisory authorities is
    available here: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm.
  • The right to withdraw consent. If ExpertVoice obtains your written consent to
    collect and process your Personal Information, you can subsequently withdraw
    such consent as to any further processing of information by contacting us at
    support@expertvoice.com.
  • Automated decision-making. To the extent that ExpertVoice engages in
    decision-making based solely on automated processing, including profiling, which
    produces legal effects concerning you or which significantly affects you, you have
    the right not to be subject to such decision-making.

To exercise these rights please contact us at support@expertvoice.com. For your
protection, we may need to verify your identity before responding to your request. In the
event that we refuse a request, we will provide you a reason as to why.

You may also have the right to make a GDPR complaint to the relevant Supervisory
Authority. A list of Supervisory Authorities is available
here: https://edpb.europa.eu/about-edpb/board/members_en.

RIGHT TO OBJECT TO PROCESSING

You have the right to object to the processing of your Personal Information that is based
on legitimate interests. If you make such an objection, we will cease to process the
Personal Information unless we can demonstrate compelling legitimate grounds for the
processing which override your interests or which override your rights and freedoms, or
we can demonstrate the processing is for the establishment, exercise, or defense of
legal claims. You can object to the processing of your Personal Information by
contacting us at support@expertvoice.com.

CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION

Personal Information that you provide while in the EU, an EAA member state, or
Switzerland will be transferred to the United States. The GDPR permits such transfer
when necessary for the performance of a contract between you and ExpertVoice, if
ExpertVoice obtains your explicit consent to such transfer, or if it is ExpertVoice’s
legitimate interest to transfer the Personal Information. The laws in the United States
may not be as protective of your privacy as those in your location. If we transfer
Personal Information from the EU, UK, or Switzerland we will comply with the Privacy
Shield Principles with respect to Personal Information transferred.

RETENTION OF YOUR PERSONAL INFORMATION

We will retain your Personal Information until the Personal Information is no longer
necessary to accomplish the purpose for which it was provided. We may retain your
Personal Information for longer periods for specific purposes to the extent that we are
obliged to do so in accordance with applicable laws and regulations, to protect you,
other people, and us from fraud, abuse, an unauthorized access, as necessary to
protect our legal rights, or for certain business requirements.

SECURITY

We use a variety of technologies and processes to protect Personal Information
collected on the sites, including physical, technological, and organizational security
measures. For example, we use encryption technology whenever transmitting Personal
Information. Unfortunately, no security technology is completely secure, and you should
remember that email is not a secure means of communication. We retain Personal
Information that we collect only as long as reasonably necessary to fulfill the purposes
for which it was collected or to meet any legal requirements.

Some or all of the Personal Information we collect may be stored or processed on
servers located outside of your country, including in the United States, whose data
protection laws may differ from those where you live. As a result, this information may
be subject to access requests from governments, courts, or law enforcement in those
jurisdictions according to laws in those jurisdictions. Subject to applicable laws in such
other jurisdictions, we will use reasonable efforts to ensure that appropriate security
processes are in place to maintain protection over the Personal Information we collect.

LINKS TO OTHER WEBSITES

Our sites may contain links to websites owned by third parties. Information you share
with a third-party site is not subject to this Privacy Policy. Please review the privacy
policy of any sites you access through our sites.

CHILDREN’S PRIVACY

Our sites are not intended for use by children. We do not knowingly collect personal
information from children under the age of 16. Children under the age of 16 are
prohibited from creating an online profile.

PRIVACY POLICY CHANGES

If our Privacy Policy changes, we will post these changes to our sites with the date of
revision. Unless otherwise stated, any modifications to this Statement will go into
immediate effect after they have been posted. We encourage you to review our Privacy
Policy periodically. Your continued access to and/or use of the sites after any such
changes constitutes your acceptance of, and agreement to be legally bound by, this
Privacy Policy, as revised. If our privacy practices, including the ways we use your
Personal Information, materially change from the time you created an online profile, we
will notify you about such changes before they take effect and allow you to delete your
information as described above, should you disagree with such changes.

PRIVACY SHIELD POLICY

ExpertVoice complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S.
Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding
the collection, use, and retention of Personal Information from the European Union,
United Kingdom, and Switzerland to the United States. ExpertVoice has certified to the
Department of Commerce that it adheres to the Privacy Shield Principles. If there is any
conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the
Privacy Shield Principles shall govern. To learn more about the Privacy Shield, please
visit https://www.privacyshield.gov.

Pursuant to the Privacy Shield Frameworks, EU and UK individuals have the right to
obtain our confirmation of whether we maintain personal information relating to you in
the United States. Upon request, we will provide you with access to the personal
information that we hold about you. You may also correct, amend, or delete the
personal information we hold about you. An individual who seeks access, or who seeks
to correct, amend, or delete inaccurate data transferred to the United States under
Privacy Shield, should direct their query to support@expertvoice.com. If requested to
remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share
your data with third parties other than our agents, or before we use it for a purpose
other than which it was originally collected or subsequently authorized. To request to
limit the use and disclosure of your personal information, please submit a written
request to support@expertvoice.com.

In certain situations, we may be required to disclose personal data in response to lawful
requests by public authorities, including to meet national security or law enforcement
requirements.

ExpertVoice’s accountability for personal data that it receives in the United States under
the Privacy Shield and subsequently transfers to a third party is described in the Privacy
Shield Principles. In particular, ExpertVoice remains responsible and liable under the
Privacy Shield Principles if third-party agents that it engages to process personal data
on its behalf do so in a manner inconsistent with the Principles,
unless ExpertVoice proves that it is not responsible for the event giving rise to the
damage.

In compliance with the Privacy Shield Principles, ExpertVoice commits to resolve
complaints about your privacy and our collection or use of your personal information
transferred to the United States pursuant to Privacy Shield. European Union, United
Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first
contact us at 1-866-376-4685, support@expertvoice.com, or visit
https://www.expertvoice.com/contact.

ExpertVoice has further committed to refer unresolved privacy complaints under the
Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU
PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if
your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EUprivacy-shield/for-eu-consumers for more information and to file a complaint. This
service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under
certain conditions, you may invoke binding arbitration for some residual claims not
resolved by other redress mechanisms. See Privacy Shield Annex 1 at
https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

The Federal Trade Commission has jurisdiction over ExpertVoice’s compliance with the
Privacy Shield.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at 1-866-376-
4685 or support@expertvoice.com, or by visiting https://www.expertvoice.com/contact.

You may also contact us by writing to:
ExpertVoice
Attn: Expert Success
9 Exchange Place, Suite 1000
Salt Lake City, Utah 84111