Privacy Notice

1. Personal Information Collected

We collect information about individual users (“personal information”) as set forth below and through the means discussed below. Please note that we need certain types of information so that you can access our Services, or we can provide the Services you request. If you do not provide us with the required information, or ask us to delete it, you may no longer be able to access or use our Services.

While parts of the Services may not require you to provide any information that can directly identify you by name (such as simply browsing the Site), the specific types of information we collect will depend upon the Services you request or otherwise use and the information you choose to provide. The types of data we may collect include:

• Customer and user information, such as first and last name, email address, work address, work phone number.
• Customer transaction information, such as information about purchases or other transactions with us and information about your customer service interactions with us.
• Work-related information, such as employer and job title.
• General location information, such as country and/or state.
• Interaction data, such as information created by the interaction of a user with our Services.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online, including chat transcripts, and contents of emails you send.
• Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
• Other information. You may choose to directly provide information to us in connection with our delivery of the Services.

Personal Information You Provide to Us

We collect information that you provide directly to us. For example, we collect information from you through:

• The Services we provide, including via the Site;
• Your and your end users’ requests for customer support or technical assistance with the Services, whether those requests are made via email, web form, phone, or another means;
• Your attendance at webinars, conferences, and other online and offline events

Information We Collect Through Automated Means

When you use the Services, we collect and analyze some information via a variety of technologies that automatically or passively collect information about the Services, such as IP address, browser type(s), location (including IP address and latitude and longitude), browser language, operating system, referring and exit pages and URLs, log data, and other similar information created by automated processes.

Some of these technologies include “cookies” and may use or create anonymous identifiers, pixels, container tags and other tools that may serve and retrieve personal information, such as an IP address. Such cookies and similar files or tags may also be temporarily placed on your device. To learn more about our practices concerning cookies, please see our Cookie Notice <www.settlor.com/cookie-notice>.

Information Obtained From Customers and Third Parties

We may receive personal information about you from our customers on whose behalf we process personal information,  third-party sources such as marketing partners, social media and other cloud-based platforms, identity providers, publicly available sources, business partners, and data providers.

Recruiting and Candidate Information

If you choose to apply to work with or for Settlor through our Site or by otherwise contacting us regarding opportunities to become an agent or contractor for us, we may collect the following:

• Contact Information such as your first and last name, email and mailing addresses, phone number, professional title or profession, and company name if applicable.
• Application information regarding qualifications, skills, employment or education history, or other related information provided voluntarily in response to questions and during any interviews.
• Reference Information, such as name and contact details of your references.
• Social Media Information, such as if you provide us a link to or other access to a social media account, we may collect or access any information you permit to be shared through or from your social media account and other information depending on the social media platform.
• Background Check Information, subject to applicable law.
• Compensation informationthat you voluntarily provide and which may depend on your region and applicable laws and regulations.

You are responsible for the personal information you provide or make available to us. All personal information you provide, particularly in connection with our recruiting activities, must be truthful, accurate and not misleading in any way. You may not provide information that is obscene, defamatory, infringing, malicious, or that violates any law.

If you provide personal information of a third party, including your customers or clients, through the Services, you are responsible for providing any required notices and obtaining any consents necessary for us to collect and use such personal information as described in this Privacy Notice.

2. How We Use Your Personal Information

We, or our service providers working on behalf of us, may use your personal information for various purposes depending on the types of information we have collected from you, in order to:

• Develop, provide, deliver, and improve the Services. For example, your information is hosted and processed by our Services in order to create an account for you and to provide wireless connectivity for your network and devices. We may use such information you provide in identified, as well as in aggregated or deidentified form, to refine and improve the Services such as to add new features and improve the user experience.
• Respond to your requests for information and provide you with more effective and efficient customer service and technical support. For example, we use your information to respond to your requests for information about our Services and, if you are a current customer and submit a request for technical support, to identify you as associated with a current customer and provide more accurate and personalized technical support.
• Market, promote, and conduct advertising for the Services. For example, we use your information to send you marketing communications via email or other contact methods where permitted by applicable law.
• Operate, maintain, secure, and improve current and future Services. For example, our Services may collect your information through forms that you submit and may collect information automatically, about your use of the Services to inform us about Services performance and areas of improvement.
• Comply with any procedures, laws, and regulations which apply to us or our processing. For example, we comply with subpoenas and other court orders to process data where we have determined there is a legal requirement for us to do so.
• Establish, exercise, or defend our legal rights. We may process your personal information in connection with establishing, exercising, or defending our legal rights where it is necessary for our legitimate interests or the legitimate interests of others or for fraud prevention. For example, we may process information you provide to identify any fraudulent, harmful, unauthorized, unethical or illegal activity such as use of another individual’s identity and we may use your information as necessary to defend ourselves in litigation or enforce our rights or agreements with others.
• Conduct recruiting and hiring activities for opportunities with Settlor. If you apply to work with or for Settlor, we will review the information you submit to determine if your qualifications and experience match any available opportunities at Settlor, to verify the information you provide, communicate with you regarding any opportunities, improve our recruiting processes, process your onboarding if hired, and comply with applicable labor and employment laws.
• Other legitimate purposes as required or permitted by applicable law. We may process your information for other purposes consistent with those in this Privacy Notice and as may be permitted or required by applicable law.

Aggregate/Deidentified Data.

We may aggregate and/or deidentify any information collected through the Services so that the information can no longer be linked to you or your device. We may use the aggregated and/or deidentified information for any purpose, including without limitation for research purposes and to promote Settlor’s products and Services, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

3. How We Share and Disclose Personal Information

Settlor may share or disclose your personal information in the following ways:

• Service Providers: We provide access to or share your information with select third parties who perform services on our behalf. They have access to your information to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including network access, data storage and/or processing, billing, sales, product content and features, research, customer service, security, fraud prevention, payment processing, marketing and advertising, and legal services.
• Third Parties: We share your information with third parties to fulfill the purpose for which you have provided it. Depending on your role and use of the Services, this may or may not include the following:
  • Other customers: Sharing your information with other customers of ours or other end users who may be affiliated with other customers.
  • Required by law: Disclosing information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g., a subpoena or court order); (b) enforce this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties such as rights of privacy or intellectual property rights; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Settlor, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.
  • Partners: We may share your information with partners such as distribution or joint marketing partners pursuant to our agreements with those parties. For example, if we engage with a reseller we may share your information with such parties so they may contact you directly.
  • Business Transfers: As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including information processed in accordance with this Privacy Notice) may be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
  • Affiliates and Subsidiaries: We may share your information with our affiliates and subsidiaries to operate our business.
  • Measuring Performance: We use data for analytics and measurement to understand how our services are used. For example, we analyze data about your visits to our sites to optimize product design. And we also use data about the ads you interact with to help us understand performance of our ad campaigns. We use a variety of tools to do this, including Google Analytics. When you visit other sites or use apps that use Google Analytics, we may use tools (including cookies) that permit Google and others to link information about your activity from that site or app with activity from our Services. Please visit google.com and pages relating to Google Analytics to understand how Google uses such personal information.

4. Retention of Your Personal Information

We may retain your personal information both during and after the time you are our customer, but we typically keep it no longer than needed. The amount of time we keep it depends on the type of personal information and the purpose of processing. For example, we may retain contact information after you are a customer to maintain our internal financial or transactional records, to communicate with you about our relationship, or in cooperation with law enforcement agency requests.  We may retain information collected automatically only while the account is active.

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and used it, requirements of applicable laws, the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the resolution of any pending or threatened disputes, and enforcement of our agreements.

When we no longer can use the personal information, we will either delete or deidentify it or, if this is not possible, securely store it in accordance with this Privacy Notice and cease use of the personal information until deletion is possible. If we deidentify your personal information (so that there is no reasonable likelihood that it could be associated with an individual user and thus is no longer considered personal information under relevant law), we may retain this information for longer periods.

5. How We Protect your Personal Information

Settlor takes technical and organizational security measures to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential.

Information transmission via the internet is not completely secure. Although we use measures designed to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures by you or by third parties.

6. Children’s Privacy

The Services are not for children under the age of 18. If we become aware that we have inadvertently collected or received personal information from children under the age of 18 without valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of children under the age of 18 without parental consent.

7. Rights and Choices

You may choose not to provide personal information. If you choose not to provide personal information (or ask us to delete it), we may not be able to provide you with our Services or certain functionality of the Services.

You may instruct us not to use certain optional information if you contact us by emailing us as set forth below. Please note that, regardless of your request, we may still use and share certain information as permitted by applicable law. For example, you may not opt out of certain operational or transactional emails, such as those reflecting our relationship or transactions with you, or important notifications regarding the Services we are providing to you.

If your request relates to personal data that may be processed on behalf of one of our customers, note that such customer exclusively determines how your personal information is processed, as well as if and how your request should be handled, so we may advise that you submit your request directly to them.

8. Third-Party Sites and Applications

Our Services may provide links to or make available integrations with third-party websites or applications (“Third-Party Sites”).  Such Third-Party Sites are outside our control and not covered by this Privacy Notice. Settlor is not liable for any information, content, products, services, software, or other materials available on or through Third-Party Sites. The use of a Third-Party Site or any information or other content found on Third-Party Sites is subject to and governed by the terms and conditions of such Third-Party Sites. We encourage you to review the privacy notices posted on such Third-Party Sites.

9. Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at any time to reflect changes in the law, our data collection and use practices, our Services, or advances in technology. We will make the revised Privacy Notice accessible through the Services, so you should review the Privacy Notice periodically. By continuing to access the Services, you are confirming you have read and understand the latest version of this Privacy Notice.

10. Contact Information

Please feel free to contact us if you have any questions about this Privacy Notice or our associated information practices.  You may contact us as follows:

Settlor, Inc.
3840 York Street, Suite 200
Denver, CO 80205
legal@settlor.com

Last updated: July 2023