Privacy Statement

Effective: August 27, 2020

At UberEther, Inc. (“UberEther”, “we”, “us”, “our”), we are committed to respecting your privacy. We recognize that when you choose to provide us with information about yourself, you trust us to act in a responsible manner and to protect and safely manage any personal information that you share with us. This Privacy Statement explains who we are, how we collect, share, and use the personal information we collect about you, and how you can exercise your privacy rights.

“Personal Information” means any information that may be used to identify, relate to, describe, or that is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the bottom of this Privacy Statement.

Quick Links

We recommend that you read this Privacy Statement in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Statement, then you can click on the relevant link below to jump to that section.

  • Definitions
  • What does UberEther do?
  • Collection, Use, and Purpose Limitations of Your Information
  • Personal Information Previously Collected
  • Our Cookie Policy and Use of Other Tracking Technologies
  • Disclosures, Sharing and Onward Transfers of Your Information
  • Legal Basis for Processing Personal Information (EEA and Swiss visitors only)
  • Security
  • Data Retention
  • Your Data Protection Rights and Choices
  • California Residents’ Rights
  • Privacy Policies of Third Party Services and Third Party Websites
  • Change Management of Privacy Statement
  • Children’s Personal Information Policy
  • Contact Information

Definitions

“Affiliates” refers to present or future companies that, directly or indirectly, through one or more intermediaries, control, are controlled by, or are under common control with UberEther.

“Materials” refers to the software, courseware, toolkits, documentation, and all other information, whether tangible or intangible, that UberEther makes available on its websites or through customer engagements.

“Services” refers to the services provided by UberEther, including the Software Extensions and those provided in connection with the Materials, as well as any other related education or training services provided by or through.

“Support Portal” refers to the product-idea and support-case portal for UberEther customers and partners, http://support.uberether.com/, and related materials.

“Third Party Services” refers to third party data rooms, channels, and services provided by Slack, Inc., Smartsheet, Inc., Box, Inc, or other third-party service providers that UberEther may grant you access to, and use of, for the purposes of collaborating and sharing information with UberEther.

“Users” refers to individuals who use the Services or Third-Party Services.

“Visitors” refers to individuals who visit a Website.

“Website” refers to the website www.uberether.com and all other related sub-domains, including Auth.ly and Support Portal, each of which includes text, media, documentation, pictures, and other content.

What does UberEther do?

UberEther is a provider of enterprise identity and cloud software and services, headquartered in the United States.

For more information about UberEther please see the “About” section of our Website at https://www.uberether.com/about/.

Collection, Use, and Purpose Limitations of Your Information

We collect Personal Information about you from a variety of sources, including directly or automatically from you, from third-party sites and businesses, as well as from publicly available information.

Information you provide voluntarily:

Certain parts of our Website, Services, and Third Party Services may ask you to provide Personal Information voluntarily.  For example, we may collect personal identifiers such as your name, email address, and phone number, and professional information such as your occupation and place of employment in order to register an account with us, to make use of our Services, to subscribe to marketing communications from us, to engage with a member of our team regarding your use of our Services, or in submitting inquiries to us.

When you participate in, access, use, or sign up to receive Services, Third Party Services, activities, or online content, such as email publications, blogs, newsletters, competitions, live chats, message boards, vote, or create an account using UberEther’s online registration system (e.g., for Support Portal or Third Party Services), UberEther may receive Personal Information about you, including personal identifiers and professional information, that we use to provide our identity management and governance services to our business customers. In comments you post to blogs, competitions, live chats, or message boards, you may also voluntarily disclose additional categories of Personal Information, depending on the content of your posts.

Automatic Collection of Information:

When you visit our Website, UberEther will gather internet activity information about your visit and your device automatically, including how you found or were directed to or used the Website and the name and URL of the website that you visited immediately preceding your visit to our Website. Please see our cookie policy for more information.  UberEther may use this type of information internally, on a cumulative basis, to better understand what pages Visitors and prospective customers access or visit. UberEther may aggregate internet activity information, combine it with other information, and disclose it to business and trade partners as well as UberEther’s Affiliates. For information on who we share your information with, and why, please see “Disclosures, Sharing, and Onward Transfers of Your Information” below [Disclosures, Sharing, and Onward Transfers of Your Information].

Payment Processors:

UberEther may use certain third-party payment processors, including Stripe, Inc., (“Payment Processors”) to collect and process personal financial information from Visitors such as name, phone number, address, zip postal code, and credit card or bank account information for the purposes of allowing Visitors to purchase various items, including Materials or Services, via our Website. If you make any payment through our Website, your credit card and other billing details may be gathered and stored with our trusted Payment Processors for the purpose of completing your purchases. UberEther does not store your credit card or billing details, and such details cannot be accessed by UberEther’s staff. UberEther contractually requires that its Payment Processors, including Stripe, stay compliant with the Payment Card Industry Data Security Standards, as well as all applicable local, state, national and international laws and regulations related to the services provided to UberEther by such Payment Processors.

Forum Posts:

UberEther may also receive information from you via any blogs, forums, or comments pages that are maintained within the Website or Third Party Services. Note that if you provide any Personal Information via any such pages maintained or used for public comment, your information will be publicly available to any other User or Visitor.

Personal Information Previously Collected

In the 12 months prior to the date of this Privacy Policy, we may have collected the categories of Personal Information identified above [Collection, Use and Purpose Limitations of Your Information] and disclosed them to the same parties for the same purposes as described above.

Our Cookie Policy and Use of Other Tracking Technologies

From time to time, some of UberEther’s Websites may utilize “cookies” and other tracking technologies. When you visit our Website, UberEther may place one or more “cookies” on your computer. A “cookie” is a small text file that may be used, for example, to collect information about website activity. Some cookies and other technologies may serve to recall Personal Information previously provided by a Website Visitor. UberEther uses cookies for all or any of the following purposes:

  • Identify you when you access, visit, or log-in to any Website. This enables you to re-visit any Website without having to re-enter information upon each visit.
  • To note different areas of any Website which have recently been accessed through your computer. Information collected in this way may be used to develop and manage the online services of UberEther by, for example, storing information about your preferences so as to enable UberEther to customize any Website according to your individual interests.
  • Delivering content on any Website which is relevant to your individual interest.
  • Monitoring the effectiveness of any promotions or marketing campaigns by UberEther or its Affiliates.
  • Tracking your entries, submissions, and status in promotions, sweepstakes, and contests.
  • Improving any Website content and conducting various other diagnostics to improve UberEther’s services. UberEther may, for example, use cookies to monitor aggregate metrics such as the total number of visitors and pages viewed.
  • Analyzing and improving Website security.

The Websites do not respond to “do not track” signals from browsers. Thus, your selection of the “do not track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. To effectively manage our collection of cookie information, you may set most browsers to notify you if you receive a cookie, or you may choose to block cookies through the settings associated with your browser. But, please note that if you choose to erase or block cookies, you will need to re-enter your original information (e.g., user name, password, or general contact info) to gain access to certain parts of the Websites and may not be able to access other parts of the Websites.

UberEther may also use tracking technologies that record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that any Website is accessed by Visitors. UberEther may also analyze information for trends and statistics, such as through the use of Google Analytics or other similar analytics services.

For more information about cookies please see the “Cookie Notice” section of our Website at Cookie Notice.

Disclosures, Sharing and Onward Transfers of Your Information

Who does UberEther share my Personal Information with?

We may disclose your Personal Information to the following categories of recipients:

  • to our group companies, affiliates, third party services providers, and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website, Third Party Services or Services), or who otherwise process Personal Information for purposes that are described in this Privacy Statement or otherwise notified to you when we collect your Personal Information;
  • to the third parties that provide the Third Party Services for the purposes described in this Privacy Statement and each third party’s privacy statement;
  • to any competent law enforcement body, regulatory, government agency, court, or other third parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights and property, or (iii) to protect your rights, property or safety or those of any other person;
  • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger, or acquisition of assets or any part of our business; and
  • to any other person with your consent to the disclosure.

International data transfers

Your Personal Information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective).

Specifically, our Website servers are located in the United States, and our third-party service providers and partners operate around the world. This means that when we collect your Personal Information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Statement.

Privacy Shield

Where Personal Information originates from the European Economic Area or Switzerland and is transferred to the United States, UberEther agrees to comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, respectively. UberEther makes an affirmative commitment to adhere to EU-U.S. and Swiss-U.S. Privacy Shield Principles (the “Privacy Shield Principles”). With respect to such Personal Information, to the extent of any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles govern. More information on the EU-U.S. and Swiss-U.S. Privacy Shield programs can be found at https://www.privacyshield.gov.

In the context of an onward transfer, UberEther has responsibility for processing Personal Information it receives under Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Where required by Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EEA and Swiss Personal Information in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EEA or Swiss Personal Data that we transfer to them.

On July 16, 2020, the Court of Justice of the European Union issued a judgment which made the Privacy Shield Framework no longer a valid mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States. However, UberEther continues to honor its commitments under the EU-U.S. Privacy Shield Framework, along with reliance on alternative mechanisms to legitimize international personal data transfers.

Legal basis for processing Personal Information (EEA and Swiss visitors only)

If you are a User or Visitor from the European Economic Area or Switzerland, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect Personal Information from you only (i) where we need the Personal Information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the “Contact Information” heading below [Contact Information].

Security

Wherever your Personal Information may be held within UberEther or on its behalf, UberEther takes reasonable and appropriate steps to protect the Personal Information that you share with us from unauthorized access or disclosure. UberEther trains its employees on data handling practices. In addition, UberEther and its business partners enter into confidentiality agreements which require that care and precautions be taken to prevent loss, misuse, or disclosure of your Personal Information.

However, while we attempt to ensure the integrity and security of Personal Information, please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, although UberEther complies with its legal obligations in respect of the security of your personal data we cannot guarantee its absolute security.

Data retention

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

Your data protection rights and choices

  • If you wish to make a request to access, correct, update or delete your Personal Information, you can do so at any time by contacting us using the contact details provided under the “Contact Information” heading below [Contact Information].  If you are a California resident, see below for additional information.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Contact Information” heading below [Contact Information].

If you are a resident of the European Economic Area or Switzerland, you can also:

  • object to the processing of your Personal Information, ask us to restrict the processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact Information” heading below [Contact Information].
  • 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 the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to 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.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

California Residents’ Rights

If you are a California resident whose information is covered by the California Consumer Privacy Act (the “CCPA”), you may have certain rights regarding Personal Information we may have collected about you, as described in this below. 

Those rights include (a) the right to access specific pieces of Personal Information we have collected about you in the 12 months prior to receipt of a verified request, and (b) the right to know about the categories of Personal Information we collected about you, the categories of sources from which that information was collected, the purpose for collection, and/or the categories of Personal Information we have shared with third parties and the categories of those third parties, all within the 12 months preceding your verified request. 

You may also have the right to request the deletion of Personal Information we have collected about you that is covered by the CCPA, subject to various exceptions in the CCPA. 

These rights to access, know about or delete Personal Information do not apply to Personal Information we may have collected in the course of certain business-to-business transactions or in the human resources context, consistent with the CCPA.  

We do not sell the Personal Information of California residents.

Submitting CCPA requests

You may submit a request for Personal Information consistent with this section by emailing us at privacy@uberether.com or 1-877-378-1220.

Depending on the nature of your request, we may ask you for information to verify your request and identity. 

Please note that you may designate an agent to submit requests on your behalf.  Any such agent will have to verify their identity and we will require a separate verifiable confirmation from you that you have authorized the agent to act on your behalf.  

Non-discrimination

We are committed to complying with the law. If you exercise any of the rights explained in this Policy, we will continue to treat you fairly.

We are a CCPA Service Provider

UberEther primarily operates as a “service provider,” as that term is defined in the CCPA, for its customers.  This means UberEther primarily collects and/or processes Personal Information on behalf of its customers, for customers’ business purposes, pursuant to written agreements.  As a service provider, we do not use, disclose or retain Personal Information collected in its capacity as a service provider other than is necessary to perform the services for its customers as described in their agreements. 

If we receive a request to access, know about, or delete Personal Information we have collected in our capacity as a service provider, we will inform the requestor that we will not be responding because we are a service provider, and recommend you place your request directly to the business. 

Privacy Policies of Third Party Services and Third Party Websites

Our Website and Third Party Services may contain or reference links to non-UberEther websites (including the websites of the providers of Third Party Services). UberEther has no control over and assumes no responsibility for, the content, privacy policies (if any), or practices of any third party website or any link contained in a third party website. The inclusion of a link within any Website or Third Party Service does not imply any endorsement by or any affiliation with UberEther. Access to any third party website is at your own risk, and you should be aware that third-party websites may contain privacy policies that have terms that are different from that of this Privacy Statement.

In connection with your use of any Website, Service or Third Party Service, you may be made aware of services, products, articles, offers, and promotions provided by third parties, and not by us.

Finally, your use of Third Party Services may expose your data to the providers of such Third Party Services. The collection, use, and retention of your data by such third parties is governed solely by such third parties’ respective privacy policies, and UberEther has no control over how such third parties use your data.

Change Management of Privacy Statement

UberEther may amend this Privacy Statement from time to time by posting a revised policy on our Website. If UberEther makes material changes to this Privacy Statement, UberEther will endeavor to notify you of such changes (e.g., by email or an alert on any Website for a period of time). However, regularly reviewing this page is the best method to ensure you are always aware of the information UberEther collects, how it is used and under what circumstances.

You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Privacy Statement.

Children’s Personal Information Policy

UberEther does not knowingly solicit or sell any Personal Information from children under the age of 16. If UberEther is made aware that UberEther has collected Personal Information from a child under 16 years old in a manner that is inconsistent with the Children’s Online Privacy Protection Act of the United States, then UberEther will delete this information as soon as practicable.

Accessibility Policy

UberEther is committed to ensuring that our communications, including our Website, are accessible to people with disabilities.  Our Website is designed to meet recognized industry standards of accessibility.  To make accessibility-related requests or report barriers, please contact us at 1-866-282-3752 or contact us at legal@uberether.com.

Contact Information

For disputes regarding UberEther’s collection or use of your Personal Information or for more information, or questions or comments concerning the Privacy Statement, please contact UberEther at:

UberEther, Inc.
c/o Privacy Manager
23465 Rock Haven Way
Suite 150
Sterling, Virginia 20166
USA

privacy@uberether.com

You may also stop email messages and other promotional mailings by contacting UberEther at the above address or email.

Our goal is to resolve all disputes through our internal processes. If you have a complaint regarding our collection, use, disclosure or retention of Personal Information originating from the European Economic Area or Switzerland that cannot be resolved through those processes, you may:

(1) submit the complaint to the relevant data protection authorities, EU Data Protection Authorities and Swiss Federal Data Protection and Information Commissioner (FDPIC) (“DPAs”);

(2) at no cost to you, resolve the complaint through JAMS using this link: https://www.jamsadr.com/eu-us-privacy-shield; or

(3) provide notice to UberEther that you desire to resolve the complaint through binding arbitration. UberEther is subject to the enforcement powers of the U.S. Federal Trade Commission. In the event that we or such authorities determine that we did not comply with this Privacy Statement, we will take appropriate steps to address any adverse effects and to promote future compliance.

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