PRIVACY POLICY AND TERMS OF USE
Privacy Statement
Exchange Design, Inc. (“Exchange Design”) values your trust and respects your privacy interests and preferences. We are committed to full transparency in outlining what information we collect about visitors, how it is used and how you can opt-out of those programs (online or by traditional communications). This privacy policy (“Privacy Policy”) describes what information we collect about you, including when and how we collect it; how we use it; with whom we may share it; and what choices you have regarding our use of your information so that you can make informed decisions about how you use this website.
This Privacy Policy applies to all information collected and received through your communications with Exchange Design, whether electronic, written or oral; information collected through the website, evidencebase.ai/ (“Website”) that includes a link to this Privacy Policy; as well as any other information about you that we may collect offline or receive from third-parties (collectively, Sites, and offline or third-party information are referred to as the “Services”). “You” means the individual accessing or using the Website, or the company, or other legal entity on behalf of which such individual is accessing or using the Website, as applicable. “Your” has a corresponding meaning. By using this Website, You agree to the terms of this Privacy Policy. Please read the following policy to understand how Your Personal Information will be treated as You use Exchange Design’s Services. The following discloses our information gathering and dissemination practices.
By accessing our Services or providing your information to us, you accept and agree to the practices described in this Privacy Statement.
Personal Information Defined
For this Privacy Policy, “Personal Information” means information that is personally identifiable such as names, addresses, e-mail addresses, or phone numbers, as well as other non-public information that is associated with a User. Exchange Design collects and uses Personal Information as described in this Privacy Policy from the Users of our Services.
Personal Information Exchange Design Collects
Exchange Design collects the following data (“Personal Information”) upon Your consent:
Information you give us. You may give us information about you by filling in forms on our Website, when you log in to the Website, or by corresponding with us by phone, e-mail, chat, or otherwise. This includes (but is not limited to) information you provide when you use our Services and when you report a problem with our Website or the services available on it. The information you give us will depend on the circumstances but, as you are giving it to us, you will always know what information we are receiving. We may keep a record of that correspondence or information in accordance with our Data Deletion and Retention Policy[1] [2] [TT3] in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management, or otherwise as may be required by law.
Please note that we do not collect payment information from you.
Information we collect about you[4] [5] [TT6] . We may collect the following information about you:
● your contact details (phone number, address, email address).
● technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
● information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); webpage identifier; what you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), metadata information about the payload and page; analytical data; information about the DOM and mutation events; comments you choose to publicly provide; and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources[7] [8] .
● We may receive information from the third-party authentication provider about you, including your GitHub, Bitbucket, Google, or Docker username and your email address. We are also working closely with other third parties (including, for example, business partners, service providers, sub-contractors in technical and payment services, advertising networks, analytics providers, search information providers and recruitment agencies) and may receive information about you from them. If you use the Website while working for one of our customers, we will receive information (such as your email address, to create an account for you) from that customer. If you work for an organization, we may receive your name and contact details from partners who identify for us potential customers for our services (including attendees at events we sponsor).
Uses made of the Personal Information[9] [10]
This information might be used to send you product recommendations, articles via a newsletter, or more information about a particular technology vendor, depending on the form you fill out and the consent you provide at the time you fill out that form.
We use information held about you in the following ways:
● to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
● to provide customer support;
● to personalize your experience;
● to contact you about your account;
● where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
● to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
● to provide you with our newsletter, security best practices and updates about our Website;
● to provide you with information about goods or services we feel may interest you;
● to notify you about changes to our Services;
● to administer our Website and our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
● to improve our Website and our Services and to ensure that content is presented in the most effective manner for you and for your computer or mobile device; and
● as part of our efforts to keep our Website safe and secure.
Exchange Design collects the following Personal Information that You submit voluntarily. You may provide Exchange Design with additional information about You as You use the Services such as:
● physical addresses
● telephone numbers
● information regarding Your business (e.g., business name, revenue thresholds, etc.)
● information regarding Your business needs and technology requirements
● other personally identifiable information You affirmatively provide to us such as LinkedIn profile information
Please be aware that while some pieces of information that You provide to Exchange Design would not be sufficient to identify You when seen by another User without any context, the combination of different pieces of information that You have provided for viewing by other Users, or any contextual information, may allow other Users and Exchange Design to identify You.
When You contact Exchange Design by sending Exchange Design an e-mail or when You use any of our contact forms, Exchange Design will collect any information that is contained in (and/or attached to) Your e-mail, text message, or that You enter into such forms.
Exchange Design does not collect, process, or control any sensitive personal information such as Physical or Mental Health, Political Beliefs or Genetics, etc.
Legal Grounds for Processing Information under GDPR
For our direct marketing activities, we employ Legitimate Interest as legal grounds for processing data.
Browsing the Website[11] [12] [TT13]
If You browse through the Website without entering any Personal Information, Exchange Design will automatically gather and store certain information about Your visit. This information does not identify You personally and cannot be linked back to You unless You decide at some point to identify Yourself. If You are only browsing, Exchange Design may collect the following information (whenever possible): IP address, domain name, the type of browser and operating system used to access the Website, the date and time You access the Website, the pages You visit (click-through), and if You linked to the Website from another website, the address of that website as well as additional information related to Your visit. Exchange Design uses Your IP address to help diagnose problems with our server, and to administer the Website.
Cookies
Exchange Design may place “cookies” on Your personal computer. “Cookies” are small identifiers sent from a web server and stored on Your computer’s hard drive, similar to a license plate, that help Exchange Design to recognize You if You visit the Website again. Exchange Design use cookies to record session information, such as record user-specific information on what pages You access or visit, record past activity in order to provide better service when You return to the Website, ensure that You are not repeatedly sent the same banner ads, to customize Website content based on Your browser type, and to track how You found the Website. Cookies are not designed to be used to get data from Your hard drive, Your e-mail or any other personal data about You.
To protect Your privacy, Exchange Design does not use cookies to store or transmit any Personal Information about You on the Internet. You can reject cookies by changing Your browser settings. Please note, however, that if You reject our cookies, it is possible that some web pages may not properly load, Your access to certain information might be denied or You might have to enter information about Yourself more than once.
For more information, please visit our Cookie Policy here[14] [15] .
Minors
Exchange Design does not knowingly collect personally identifiable information[16] [17] by anyone under the age of 18. Do not fill out any forms on the site if You are under the age of 18 and do not provide Exchange Design with any information regarding any individual under the age of 18.
Use of Personal Information
Personal Information You submit to Exchange Design, or to third parties that support us in collecting information, is used by us to provide You and other Users with the Services, to respond to requests that You make, to improve our Services, and to operate, maintain, and improve the features, functionality, performance, and support of the Services.
Exchange Design uses the Personal Information that it gathers about You for the following purposes:
● To provide our Services to You, to communicate with You about Your use of the Services, to respond to Your inquiries, to fulfill Your orders, and for other customer service purposes, which may include communicating with You via email
● To tailor the content and information that Exchange Design may send or display to You, personalized help and instructions, and to otherwise personalize Your experiences while using the Website or the Services
● To share with website affiliates, and/or vendors of products You have given us consent to contact You regarding products or services as a means of establishing communication between both You and such vendors or affiliates.
● For marketing and promotional purposes. For example, Exchange Design may use information You provide to contact You in the manner(s) You request at the time that data is collected. Exchange Design may collect your email address to send You news and newsletters, special offers and promotions, or to otherwise contact You about products or information You expressed interest in. Exchange Design also may use the information that Exchange Design learns about You to assist us in advertising our Services on third party websites.
● To better understand how users access and use the Website and Services, both on an aggregated and individualized basis, to improve the Website and Services and respond to user desires and preferences, and for other research and analytical purposes
Feedback
If You provide feedback about the Services, Exchange Design may use and disclose such feedback for any purpose, provided Exchange Design does not associate such feedback with Your Personal Information. Exchange Design will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy.
Disclosure of Personal Information
Except as otherwise stated in this Privacy Policy, Exchange Design does not disclose to or share Your Personal Information with third parties, unless You ask or authorize Exchange Design to do so. Exchange Design may provide Your Personal Information to third party service providers and suppliers who work on behalf of or with Exchange Design to provide You with some of the services and features of the Services and to help us communicate with Users. However, these service providers and suppliers do not have any independent right to use this information except to help Exchange Design provide the Services. Exchange Design may share some or all of Your Personal Information with any parent company, subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), in which case Exchange Design will require Affiliates to honor this Privacy Policy.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of a dispute in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Unused data and data that falls outside of categories we deem commercially viable will be deleted. To ensure the accuracy of our recommendations and the privacy of Personal Information, Exchange Design analyzes all records annually and deletes any that have gone untouched, unprocessed, and unreferenced in a timespan of five (5) years. Data that has been requested to be forgotten will be deleted promptly.
For more information, visit our Data Retention & Destruction Policy here[18] [19] [TT20] .
Mergers
In the event Exchange Design goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, Your Personal Information will likely be among the assets transferred. You acknowledge that such transfers may occur, and that any acquirer of Exchange Design or its assets may continue to use Your Personal Information as set forth in this Privacy Policy.
Legal Obligation to Disclose
Exchange Design may (and You authorize us to) disclose information Exchange Design has collected from and about You (including Personal Information) if Exchange Design believes in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to enforce our Exchange Design Privacy Policy; or (c) to protect and defend the rights or property of us, the users of our Services, or third parties.
Data Compliance
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
Exchange Design adheres to the rights of data subjects set out by the GDPR standards. If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Exchange Design aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
Under these standards, individual citizens of the European Union (EU) and the European Economic Area (EEA) have the right to:
● The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
● The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
● The right to object. You have the right to object to our processing of your personal data.
● The right of restriction. You have the right to request that we restrict the processing of your personal information.
● The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
● The right to withdraw consent. You also have the right to withdraw your consent at any time where the Company relied on your consent to process your personal information.
If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
If You would like to make a subject access request (“SAR”) to view, delete, or otherwise change the data stored in the Exchange Design database, please contact our Data Requests team by emailing support@exchange.design.
CCPA (California Consumer Privacy Act)
Through our site and partners, we receive data that you actively submit, as well as data that we track when you request information, or otherwise actively send us data. We usually collect data such as your name, email address, business address, telephone number, and other information related to the business you represent.
Exchange Design adheres to rights of data subjects set out by CCPA. Residents of California upon verification have the right to
The right to know which personal information is being collected.
The right to know if personal data is being sold or shared, and to whom.
The right to object to the sale of personal data.
The right to access one’s own personal information.
The right to equal service and price, even for consumers who exercise their privacy rights.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise these rights listed above you can contact us by
Email us at support@exchange.design
Or Mail us at
Exchange Design
Attn: Data Requests
328 E. Mason Ave
Alexandria, VA 22301
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Security
Exchange Design works hard to protect Information You provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Exchange Design has deployed all of these requirements in our systems and processes both internally as well as with upstream data providers to ensure the security of Personal Information:
● Hardware-level and/or software-level encryption
● Data minimization
● Data pseudonymization
● Data encryption at rest
● Data encryption in transit
Information Sharing
On occasion Exchange Design will make available to potential advertisers, research firms, and business partners aggregated results from research it has conducted regarding visitors to the Website. Exchange Design may count, track, and aggregate visitor activity into our analysis of general traffic flows to the Website and may merge this information into group data, which may then be shared on an aggregated basis with potential advertisers, research firms, and business partners. In such case, Exchange Design will only provide demographic information on an aggregated basis and does not disclose individual reader information.
Links to Other Web Sites
The Website may contain links to Third Party Sites that are not owned or controlled by Exchange Design. The provision of such links is for Your convenience and does not signify Exchange Design’s endorsement of such web sites or location or its contents. Exchange Design has no control over, does not review and is not responsible for the privacy policies of or content displayed on Third Party Sites. Please be aware that the terms of this Privacy Policy do not apply to Third Party Sites
DISCLOSURE: Exchange Design may have affiliate marketing agreements set up with a portion of the products mentioned in blog posts or other pages on the site. If a user clicks through to a product from channelinsider.com and makes a purchase, Exchange Design may be entitled to a portion of the revenue generated from this purchase.
Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out below, please contact us at support@exchange.design.
If you would like to exercise your data privacy rights as applicable to your location of residence, please follow this link [link to Opt-Out Form].
If you are needing to contact legal/DPO - email support@exchange.design.
You have the right to:
Request access to your Personal Information or personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Notification of Privacy Statement Changes
From time to time, Exchange Design may use Personal Information for new, unanticipated uses not previously disclosed in this Privacy Policy. If Exchange Design’s information practices change at some time in the future Exchange Design will post the policy changes to this Website to notify You of these changes and provide You with the ability to opt out of these new uses. If You are concerned about how Your information is used, You should check back at this Website periodically.
Contacting the Exchange Design Data Protection Team
If You have any questions about this Privacy Policy, the practices of this Website, or Your dealings with this Website, please contact the Exchange Design Data Request Team at support@exchange.design.