Privacy Policy

January 2nd, 2020

Epee Consulting, LLC. (“Epee”) is committed to protecting your privacy and ensuring you have a positive experience on our website and in using our services. This policy covers the Epee website, mobile applications, and desktop clients and is applicable worldwide.

This policy outlines our handling practices and how we collect and use the Personal Data you provide during your online and offline interactions with us. As used in this Privacy Policy, “Personal Data” means any information that can be used to individually identify a person, and may include, but is not limited to, name, email address, postal or other physical address, credit or debit card number,
title, and other personally identifiable information.

If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.

Epee Consulting, LLC will be the Controller of your Personal Data that is provided, collected and/or processed pursuant to this Privacy Policy in order to, for example, respond to requests for information or service, conclude a business transaction, provision the service, or otherwise for Epee’s business purposes. Epee will be a Processor of data that is entered into the service when a Customer uses the Services (see “User-Generated Information”, below.). Epee is not a Processor of financial data (e.g. credit cards, PayPal, etc.), such data resides exclusively with Stripe for processing transactions and Epee has no access to it. If you have any questions about whether any of foregoing applies to you, please contact us using the information set forth in the “Contact Us” section below.

This policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our website. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Collection of your Personal Data
We may collect, either as Controller or Processor, the following categories of Personal Data about you when you use or otherwise interact with our Service:

• Name
• Username
• Title
• Email address
• Home/work/mobile telephone number
• Postal or other physical address
• Name of your University or Company
• Year in School or working professional
• Engineering discipline
• Industry of interest
• Recommended and/or selected classes
• IP addresses and other information collected passively, as further detailed in the “Passive Collection” section below
• Device identifiers, as further described in the “Mobile Application” section below
• Our service partner’s servers automatically record certain information when you use the Service, including your IP address, operating system type and version, client version, IP addresses along the network path, and the MAC address of your internet connection (“Host
  Information”)
• Our service partners AWS and Zoom automatically record information about your usage of the Service, including actions taken, date and time, frequency, duration, quantity, quality, network connectivity, and performance information related to logins, clicks, messages,
  contacts, content shared, calls, use of video and screen sharing, meetings, cloud recording, and other feature usage information (“Usage Information”)
• Other information you upload, provide, or create while using the Service (“User-Generated Information”), as further detailed in the “User Generated Information” section below

User-Generated Information
We collect and retain, generally as a Processor and in order to provide the Services, Personal Data and other information you upload, provide, or create while using the Service (“User-Generated Information”), including information related to:

• Online sessions: We will record meeting title, invitation content, participants, meeting link, date, time and duration. We collect activity recorded in the meeting (such as joining or leaving), including activity related to third-party integrations, together with the date, time, person engaged in the activity, and other participants in the meeting with the date, time, duration, and quality ratings that you provide. We record audio and video from each class to be used within the class archive for offline access. Use data is also used to determine if a participant actively attended the session, which determines if they are/are not eligible to receive a certificate of completion.
• Messages: Message content, sender and recipients, date, time, and read receipts. Content shared: Files and file names, sizes, and types
• Polling: Polling results from classes will be recorded, but no personally identifying data is available.
• Whiteboards: Whiteboard content, snapshots, and background images

All messages and content you share in a meeting, including Personal Data about you or others, will be available to all other participants in that meeting.

Passive Collection

Epee and our third-party service providers automatically collect some information about you when you use our services, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website.

In addition, when you use some of our services, network information is transmitted back to us such as usage information. This information is transmitted back to us, so we can determine how users are interacting with our services, to assist us with improving our services, and to correct any problems that may occur.

Mobile Application

When you download and use our services, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID”). We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you can turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

Processing of your Personal Data

We will use your Personal Data only in accordance with our Privacy Policy. If you do not wish us to continue using your Personal Data in this manner, you can request that your account be deactivated by contacting us as specified in the “Contact Us” section.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your user agreement with us that allows us to provide you with the services) and our “legitimate interests” or the legitimate interest of others (e.g. our users),

We process Personal Data when you use our website, desktop client and mobile applications to use or sign-up to use our Service for purposes such as:

• Account configuration
• Account maintenance
• Enabling meetings and webinars between hosts and users
• Hosting and storing personal data from meetings and webinars (only to provide the Service)
• Personalizing, improving or operating our Service and business
• Fulfilling requests you make related to the Service
• Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity
• Providing reports based on information collected from use of our Service
• Processing your orders and deliver the Service that you have ordered
• Providing support and assistance for our Service
• Providing the ability to create personal profile areas and view protected content
• Providing the ability to contact you
• Providing customer feedback and support
• Complying with our contractual and legal obligations, resolving disputes with users, enforcing our agreements

We process Personal Data when you visit our website to:

• To keep you up to date on the latest Product announcements, software updates, software upgrades, system enhancements, special offers, and other information
• To provide customer feedback and support
• To provide and administer marketing or promotional activities
• Providing you with information and offers from us
• To the extent you choose to participate, to conduct questionnaires and surveys in order to provide better products and services to our customers and end users
• To support recruitment inquiries
• To personalize marketing communications and website content based on your preferences, such as in response to your request for specific information on services of interest
• To contact individuals that you refer to us and identify you as the source of the referral, in accordance with the “Referral” section below

Referrals

If you choose to use our referral service to tell a friend about our products, you represent that you have their consent to provide us your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the website. Unless we are authorized by your friend, we will only use your friend’s name and email address for the purposes of sending this onetime email and maintaining an activity log of our referral program.

Choice

You can choose whether to provide Personal Data to Epee, but note that you may be unable to access certain options, offers, and services if they require Personal Data that you have not provided. You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by
using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this policy.

Data Subject Rights

You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.

To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.

• Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
• Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
• Erasure: You can request that we erase some or all of your Personal Data from our systems. Data subjects who want their data deleted can do so by deactivating their account. Deactivation will delete all account usage and related information. If you are not a Epee
  customer and would like your data deleted, please contact the administrator about deleting information.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Portability: You have the right to ask for a copy of your Personal Data in a machinereadable format. You can also request that we ransmit the data to another entity where technically feasible.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, Epee cannot
  guarantee that some/any of our services can be utilized without specific information. 
• Right to File Complaint: You have the right to lodge a complaint about Epee’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation. In order to make such a request of us, please contact us at admin@Epee-Education.com

Data Retention
How long we retain your Personal Data depends on the type of data and the purpose for which we process the data. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

Cookies and Tracking Technologies
Epee and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and gather information about our user base, such as location information based on IP addresses. Users can control the use of cookies at the individual browser level

Interest-Based Advertisements
We may partner with third parties to either display advertising on our website or to manage our advertising on other sites. Some of our third-party partners use technologies such as cookies and other technologies to gather information about your activities on this website, our affiliates’ websites, and unaffiliated websites in order to provide you advertising based upon your browsing activities and interests. With respect to our interest-based ads, we adhere to self-regulatory principles for online behavioral advertising issued by the Digital Advertising Alliance (“DAA”) and the European Interactive Digital Advertising Alliance (“EDAA”) (collectively, the “OBA Principles”). More information about the OBA Principles can be found at https://digitaladvertisingalliance.org/principles and https://www.edaa.eu/european-principles/.

Geolocation
Our service partner Zoom collects information about where you are located when you are using our Services. Zoom uses this information for purposes of optimizing your connection to their data centers, supporting compliance, and suggesting customizations to your experience.

Sharing your Personal Data
We do not sell or rent your Personal Data to third parties for any purposes, including marketing.

We share Personal Data within Epee and our third party service providers for purposes of data processing or storage.

Personal Data with respect to processing orders and/or credit card transactions will be completely through the applicable service vendor. Epee will not access or retain this Personal Data.

If we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy. As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.

We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Epee’s terms of service, or as otherwise required by law.

While navigating Epee’s website, you may be directed to content or functionality that is hosted by a third-party (e.g. processing financial transactions). When information is collected on behalf of Epee exclusively, Epee’s Privacy Policy will be referenced and will govern how your information is used. For other, non-Epee sites or services, the site/service owner’s privacy policy will be referenced. You should review such third party’s privacy and security policies prior to use.

Security of your Personal Data
Epee is committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. When we transfer credit card information over the Internet, we protect it using Transport Layer Security (TLS) encryption technology.

We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of upper and lower-case letters, numbers, and symbols when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal Data, you can contact us at admin@epee-education.com.

Linked websites and third-party services
Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this policy. We encourage you to review the privacy policies posted on these (and all) sites you visit or services you use.

Newsgroups/forums
If you participate in a Epee discussion forum or chat room, you should be aware that the information you provide there will be made broadly available to others, potentially inside or outside Epee, who have access to that discussion forum or chat room. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. Each participant’s opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of Epee. This includes professionals who teach a class, as they are neither employees nor contractors of Epee.

Session Recordings
We record each Epee session, and as such, any information that you may or may not provide during the live session being recorded. This information may include Personal Data, if you provide it during the session. Epee requests our users do this make public their Personal Data during our live sessions, as we will not be aware of nor have an ability to control possible exposure of such data.

For hosts — By installing or using Epee Rooms software or any other Epee software, tool or feature that allows for meeting or Webinar recording (each, a “Recording”), you acknowledge and agree that you and your company are responsible for (i) clearly notifying all individuals (whether or not they are  Epee users) who are present in a meeting or Webinar (whether in-person or remotely) (each, an “Attendee”) for which you make a Recording that such meeting or Webinar might be recorded, and (ii) obtaining any consent necessary for such a recording as required by applicable laws, rules and regulations, including without limitation data privacy laws. By making a Recording of any meeting or Webinar using any Epee Products, you and your company represent and warrant that (a) you have received legally sufficient consent from all Attendees for such recording prior to starting a Recording, (b) you will only make, use, store and otherwise process such Recording in accordance with all applicable laws, rules and regulations, including data protection laws and (c) you will store and otherwise restrict access to such Recordings using appropriate technical and organizational safeguards. Any person and/or entity who makes a Recording of a meeting or webinar shall be the data controller of that Recording, and Epee will be the data processor with respect to the Recording.

For attendees – Please be advised that any live sessions you attend will be recorded by the host. By signing up for Epee’s services or otherwise using them in any way, including without limitation by attending any Epee educational session, you expressly acknowledge that Epee may, if instructed by a meeting host, make and store Recordings, and may make such recordings available to hosts and other Attendees. If you do not want to be recorded, you can choose to leave the meeting or webinar.

Transfer and Storage of Personal Data
Our services are hosted and operated in the United States (“U.S.”) through Epee and its service providers. At this time, there are no entities within Epee operating outside the US. Should this change, by using any of our Products or providing any Personal Data for any of the purposes stated above, you consent to the transfer and storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers.

Standard Contractual Clauses
In certain cases, Epee will transfer Personal Data from the EU in accordance with the European Commission-approved Standard Contractual Clauses, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087.

Contact Us

To address your individual rights or if you have any privacy-related questions or comments related to this privacy policy, please send an email to admin@epee-education.com. You can also contact us by writing to this address:

EPEE Consulting, LLC
Attention: Data Privacy Officer
23 Green Street
Souderton, PA 18964

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request the address above.