Privacy Policy

1. What does this Privacy Policy cover?

2. What information does EGT collect, and how is it used and shared?

3. What are cookies and how do we use them and other technologies?

4. How does EGT protect personal information?

5. How long does EGT retain my personal information?

6. What are my choices concerning my personal information?

7. How is this Privacy Policy enforced?

8. What is EGT’s policy on kids’ privacy?

9. Your California Privacy Rights

10. Acknowledgment of processing within the United States

11. Changes to this Privacy Policy

12. Contacting Us

Introduction

Edmunds GovTech, Inc. (“EGT”, “we”, “our” or “us”) is committed to protecting the privacy of those who entrust us with their personal information. Our clients trust and expect that we will protect their personal information in accordance with the promises we make. “Personal information” means any information pertaining to an identified or identifiable individual and may include, for example, email addresses and contact details and any similar information provided to us in the course of our business operations by employees and residents of our Clients (see Section 2 below for a more detailed description of the categories of personal information we may collect). Information that is de-identified or anonymized is not considered personal information. This Privacy Policy details our commitment to your privacy.

1. What does this Privacy Policy cover?

We provide technology solutions that power local government (our “Clients”). This Privacy Policy describes our privacy practices regarding personal information that we receive in connection with the products and services we provide to our Clients (collectively, the “Services”), as well as through our website and our related proprietary platform(s) (collectively, the “Site”).

By using the Services or the Site, by submitting your personal information to our Clients, or by otherwise interacting with us, you are accepting the practices described in this Privacy Policy. We recommend that you review this Privacy Policy periodically, as it may be updated from time-to-time.

2. What information does EGT collect, and how is it used and shared?

For the 12-month period prior to the effective or last updated date of this Privacy Policy (see below), we explain here what categories of personal information we have collected, the purpose of collection, and how we share it:

Category of Personal Information Collected	Source	Purpose for Collection	Categories of Recipients
Contact and transaction information: such as name, mailing address, email address, phone number, tax and billing information and, as applicable, transaction details	From you when you communicate or interact with us, the Site or the Services (or, as applicable, on your behalf when you are employed or governed by a Client or when you communicate or engage in a transaction with a Client through the Site or Services)	To provide, manage, support, improve and personalize the Site and Services, and to communicate with and respond to you about the Site or Services, including to validate your identity or to meet legal obligations	Our affiliates, agents and successors; to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, a Client that employs or governs you or that sponsors or administers a program or transaction in which you participate
Employment-related information: such as name, gender, mailing address, email address, phone number, government identification number and date of birth (including with respect to healthcare dependents and beneficiaries, as applicable), time and attendance, employment eligibility (including passport or driver’s license) and tax withholding and direct deposit bank account information	From a Client that employs you (or from you when you communicate or interact with us, the Site or the Services)	To provide, manage, support, improve and personalize the Site and relevant Services	Our affiliates, agents and successors; to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, a Client that employs you
Participation-related information: such as name, gender, mailing address, email address, phone number, government identification number, driver’s license, date of birth, image or likeness, allergies, medical conditions, and injury history (including with respect to children’s program participants, as applicable)	From a Client that sponsors or administers a program in which you participate	To provide, manage, support, improve and personalize the Site and relevant Services	Our affiliates, agents and successors; to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, a Client that sponsors or administers a relevant program in which you participate
Forum information: such as information you enter into any forum or other collaborative environment or communication tool available on or through the Site or Services (as applicable)	From you when you input information into any such environment or tool	To collaborate and communicate, as contemplated by such environment or tool	Users who are authorized to view or use such environment or tool (or the applicable portion thereof) or to whom such information is communicated or designated; our affiliates, agents and successors; and, to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations)
Browsing & engagement information: such as your IP address or other device identifier, the type of browser or device you use, pages and content that you visit on the Site, what you click on, the state and country from which you access the Site or Services, date and time of your visit, and web pages you linked to the Site from; and, as applicable, your login ID and any changes, alterations or edits made via the Site	The Site or Services or your interactions with the Site or Services, including through the use of cookies or other tracking technologies explained further below	To evaluate usage of the Site and Services and improve functionality and performance; to protect the security and integrity of the Site and Services and our business, such as preventing fraud, hacking, and other criminal activity or to meet legal obligations	Our service providers who help us with fraud protection and website analytics
Payment information: such as name, card issuer and card type, and billing address; and, if applicable, credit or debit card number, expiration date, and CVV code	From you or your payment card issuers (or, as applicable, on your behalf when you engage in a transaction with a Client through the Site or Services)	Authorizing of credit card and other financial transactions with respect to your subscription or other payment obligations, as applicable, related to the Site or Services (or, as applicable, transactions with a Client)	Our service providers who process payments for us; they are prohibited from using personal information for any other purposes and are contractually required to comply with all applicable laws and requirements, which includes the Payment Card Industry Data Security standards
Legal process-related information: such as details of your identity, or suspected or alleged criminal, dangerous, impermissible, unlawful, or other relevant behavior	From crime and fraud prevention agencies, you, witnesses, or law enforcement agencies	To protect users (and other data subjects), the public, and our business against risks and crime	Law enforcement and other governmental authorities in accordance with applicable law, our technical and other service providers, and our professional advisors

Category of Personal
Information Collected

Source

Purpose for Collection

Categories of Recipients

Contact and transaction information: such as name, mailing address, email address, phone number, tax and billing information and, as applicable, transaction details

From you when you communicate or interact with us, the Site or the Services (or, as applicable, on your behalf when you are employed or governed by a Client or when you communicate or engage in a transaction with a Client through the Site or Services)

To provide, manage, support, improve and personalize the Site and Services, and to communicate with and respond to you about the Site or Services, including to validate your identity or to meet legal obligations

Our affiliates, agents and successors; to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, a Client that employs or governs you or that sponsors or administers a program or transaction in which you participate

Employment-related information: such as name, gender, mailing address, email address, phone number, government identification number and date of birth (including with respect to healthcare dependents and beneficiaries, as applicable), time and attendance, employment eligibility (including passport or driver’s license) and tax withholding and direct deposit bank account information

From a Client that employs you (or from you when you communicate or interact with us, the Site or the Services)

To provide, manage, support, improve and personalize the Site and relevant Services

Participation-related information: such as name, gender, mailing address, email address, phone number, government identification number, driver’s license, date of birth, image or likeness, allergies, medical conditions, and injury history (including with respect to children’s program participants, as applicable)

From a Client that sponsors or administers a program in which you participate

To provide, manage, support, improve and personalize the Site and relevant Services

Our affiliates, agents and successors; to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, a Client that sponsors or administers a relevant program in which you participate

Forum information: such as information you enter into any forum or other collaborative environment or communication tool available on or through the Site or Services (as applicable)

From you when you input information into any such environment or tool

To collaborate and communicate, as contemplated by such environment or tool

Users who are authorized to view or use such environment or tool (or the applicable portion thereof) or to whom such information is communicated or designated; our affiliates, agents and successors; and, to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations)

Browsing & engagement information: such as your IP address or other device identifier, the type of browser or device you use, pages and content that you visit on the Site, what you click on, the state and country from which you access the Site or Services, date and time of your visit, and web pages you linked to the Site from; and, as applicable, your login ID and any changes, alterations or edits made via the Site

The Site or Services or your interactions with the Site or Services, including through the use of cookies or other tracking technologies explained further below

To evaluate usage of the Site and Services and improve functionality and performance; to protect the security and integrity of the Site and Services and our business, such as preventing fraud, hacking, and other criminal activity or to meet legal obligations

Our service providers who help us with fraud protection and website analytics

Payment information: such as name, card issuer and card type, and billing address; and, if applicable, credit or debit card number, expiration date, and CVV code

From you or your payment card issuers (or, as applicable, on your behalf when you engage in a transaction with a Client through the Site or Services)

Authorizing of credit card and other financial transactions with respect to your subscription or other payment obligations, as applicable, related to the Site or Services (or, as applicable, transactions with a Client)

Our service providers who process payments for us; they are prohibited from using personal information for any other purposes and are contractually required to comply with all applicable laws and requirements, which includes the Payment Card Industry Data Security standards

Legal process-related information: such as details of your identity, or suspected or alleged criminal, dangerous, impermissible, unlawful, or other relevant behavior

From crime and fraud prevention agencies, you, witnesses, or law enforcement agencies

To protect users (and other data subjects), the public, and our business against risks and crime

Law enforcement and other governmental authorities in accordance with applicable law, our technical and other service providers, and our professional advisors

We will only use personal information to the extent it is reasonably necessary to deliver, manage, support, improve or personalize the Services or the Site or to otherwise fulfill the described or relevant purpose for which such information is provided or collected. In all cases, any service providers will be contractually limited in the way they may use personal information maintained by us, including requirements that such information is maintained in a confidential and secure manner.

In Connection with Business Transfers: In the event that a division, a product, or all of EGT is acquired, sold, or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to Client contractual requirements and applicable law.

To Comply with Laws: We may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry, or other litigation processes. We may also disclose information to our accountants, auditors, agents, lawyers, and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our users or others, in accordance with or as authorized by law.

3. What are cookies and how do we use them and other technologies?

A cookie is a small piece of information that a website, online application, or email may save to your browser or your computer’s hard drive for use in subsequent visits to the website or online application. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies or how to disable cookies altogether. If you disable cookies, certain features or functionality of the Site or Services may be limited or otherwise adversely impacted. We do not control and do not guarantee the effectiveness of browser-based tools for managing cookies.

We do not currently participate in interest-based or behavioral online advertising, and information automatically collected from the Site is not used by us for that purpose.

We may use Google Analytics to evaluate the use of the Site for our internal purposes such as evaluating usages of the Site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at: www.google.com/policies/privacy/partners

Any and all personal information collected on the Site will be kept strictly confidential and will not be sold, reused, rented, disclosed, or loaned to third parties, except as otherwise described in this Privacy Policy.

Do Not Track (DNT): This is a privacy preference that users can set in some web browsers, allowing users to opt-out of tracking by websites and online services. At the present time, the World Wide Web Consortium, or W3C, has not yet established universal standards for recognizable DNT signals, and therefore EGT and the Site do not recognize DNT.

4. How does EGT protect personal information?

Where applicable, we use industry-standard technology in connection with the Services and the Site to help protect personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. Personal information transmitted to us by our Clients through the Site or Services is stored on servers that we have attempted to secure from unauthorized access or intrusion. We will notify Clients of any loss of data or breach of our security measures which has resulted in the loss or unauthorized access, disclosure, use, or acquisition of such Client’s personal information, as required by law.

5. How long does EGT retain my personal information?

Personal information that we collect, access, or process will be retained only as long as necessary for the fulfillment of the purposes for which it was collected unless otherwise provided for under services contracts with Clients or as required or authorized by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased, or de-identified.

6. What are my choices concerning my personal information?

Our Clients are responsible for notification of purpose and for obtaining appropriate consent, to the extent required by law, when they collect personal information that is transferred to us.

Our Clients are responsible for ensuring that any commercial emails sent by them comply with applicable law. If we are instructed by our Clients to transmit communications on their behalf, Clients remain responsible (and we assume no responsibility) for ensuring that recipients have consented to receive such communications and that the information contained in the communications are accurate and complete.

We do not sell, rent, or share the personal information of our users (or other data subjects) with third parties for such third parties’ own marketing purposes; provided that, for clarity, we may share personal information of our Clients’ residents with our applicable Clients as reasonably necessary in our provision of the Services.

We may, subject to applicable laws, use personal information from our users to contact them about the Site and Services, including to provide them with information on additional products or services from us that may be of interest to them. Our users may exercise choices regarding these communications as follows:

Mail marketing, Telephone marketing, Surveys, and Quality control communications. You may decide that you prefer that we do not use your personal information to promote new and/or additional products and/or services which may be of interest to you, and you may refuse that we contact you by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by contacting customer service or contacting us using the information detailed in the Contacting us section below.
Emails/Commercial Electronic Communications. You can always limit the communications that we send to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account.

7. How is this Privacy Policy enforced?

We have put in place mechanisms to monitor and verify our ongoing adherence to this Privacy Policy. We encourage individuals covered by this Privacy Policy to raise any concerns that they have about the way that we process their personal information by contacting us as described below. We take your questions and concerns seriously, and we will use commercially reasonable efforts to resolve them.

8. What is EGT’s policy on kids’ privacy?

EGT and the Site and Services are not directed toward children and we do not knowingly solicit or collect personal information online from children under the age of 13 without prior verifiable parental consent. If we learn that a child under the age of 13 has submitted personal information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under age 13, please contact us using the information detailed in the Contacting us section below.

9. Your California Privacy Rights

Note: As described above, EGT is a service provider and processor that provides the Services to local governments. If your California rights request relates to the personal information you have provided to a local government, it is unlikely that we can assist you and you should reach out directly to the relevant department of the government entity.

For personal information that you have provided directly to us through the Site or otherwise if you are a California resident, California law provides you with the following rights with respect to such personal information:

The right to know either the categories or specific personal information we have collected, used, disclosed, and sold about you. To submit a request to know, you may contact us using the contact information detailed in the Contacting us section below (with “REQUEST FOR INFORMATION” in the subject line). You also may designate an authorized agent to make a request for access on your behalf.
The right to request that we delete any such personal information we have collected about you. To submit a request for deletion, you may contact us using the contact information detailed in the Contacting us section below (with “REQUEST FOR PERSONAL INFORMATION DELETION” in the subject line). You also may designate an authorized agent to make a request for deletion on your behalf.

When you exercise these rights and submit a request to us, please provide sufficient information that enables us to verify your identity. We may follow up with you to ask for additional information to verify identity as required under California law and may use a third-party verification provider to verify your identity. Please describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in such a request to verify the requestor’s identity and to respond to such request.

The response we provide will also explain the reasons we cannot comply with the request, if applicable, such as a request to delete personal information that is necessary for us or our service providers to complete a transaction or provide a service for which we collected such personal information.

Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.

For the 12-month period prior to the effective or last updated date of this Privacy Policy (see below), we have not sold any personal information about our users (or other data subjects); nor do we have any plans to do so in the future.

10. Acknowledgment of processing within the United States

You understand that our business is based in the United States. If you are a resident of a country other than the United States or if you use the Services or Site while you are located outside of the United States, you acknowledge that we may process, store and, as applicable, transfer your personal information in or to the United States, which may not have data privacy laws that provide the same protection as such other countries. You consent to such processing, and you understand therefore that your personal information may be available to government authorities under lawful orders and laws applicable in the United States.

11. Changes to this Privacy Policy

We will review and update this Privacy Policy as required to keep current with rules and regulations, new technologies, and security standards. We will post those changes on the Site and/or update the Privacy Policy effective date below. In certain cases and if the changes are material, we will provide written notice to Clients directly by email or otherwise.

This Privacy Policy is effective as of October 1, 2020.

This Privacy Policy is incorporated into and made part of our Service Terms & Conditions, available at:
https://go.edmundsgovtech.com/terms

12. Contacting Us

If there are any questions regarding this Privacy Policy or to request a copy of this Privacy Policy in another format, you may contact us using the information below.

Edmunds GovTech, Inc.
Attn: General Counsel
privacy@edmundsgovtech.com
Toll-Free Number: 1-800-220-3754