This Website is owned and operated by, or on behalf of, Edge Delta, Inc. (“we”, “our” or “us”). We are the data controller in respect of personal information of our users based in the European Union.
INFORMATION YOU PROVIDE TO US THROUGH THE SERVICES
We collect and process information you provide directly to us via the Services. Personal data submitted through the Services include the details you submit when you create an account, participate in any interactive features of the Services, fill out a form, pay for subscriptions, apply for a job, communicate with us via third party social media sites, request customer support or otherwise communicate with us. The types of information we may collect include your name, email address, company name, postal address, phone number and any other information you choose to provide.
INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SERVICES
When you access or use the Services we automatically collect information about you, including:
Log Files: We gather certain information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to the Services, and store it in log files. We do not monitor or log data collected from your servers when using the Services, but we may log or monitor information about your access to our Services.
USE OF INFORMATION
We may use information about you to:
Enable you to have full access to the Services;
Provide, maintain and improve the Services;
Provide and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices,;
Send you technical notices, updates, security alerts, and support and administrative messages;
Respond to your comments, questions and requests, and provide customer support;
Create your Edge Delta account and identify you when you sign-in to your account in accordance with your agreement with us;
Communicate with you about products, services, offers, promotions, rewards, and events offered by Edge Delta and others, and provide news and information we think will be of interest to you;
Monitor and analyze trends, usage and activities in connection with the Services;
Detect, investigate and prevent fraud and other illegal activities and protect the rights and property of Edge Delta and others;
Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
Link or combine with information we get from others to help understand your needs and provide you with better service;
SHARING OF INFORMATION
With vendors, consultants and other service providers we have vetted and approved who need access to such information to carry out work on our behalf only to the extent necessary for the performance of any contract we enter into with you. This includes companies providing the following services for our Website and/or Platform: hosting services, authentication services, cyber security and anti-fraud services, and advertising;
In response to a request for information if we believe disclosure is permitted by, in accordance with, or required by, any applicable law, regulation or legal process such as to comply with a subpoena or applicable court order;
In connection with, or during negotiations of, any merger, sale of Edge Delta assets, financing or acquisition of all or a portion of our business by another company;
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
PRIVACY RIGHTS AND CHOICES
If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California, please refer to the respective dedicated sections below. Otherwise, at your request, and as required by applicable law, we will:
Inform you of what personal data we have about you that is under our control;
Amend or correct such personal data or any previous privacy preferences you selected, or direct you to applicable tools; and/or
Delete such personal data or direct you to applicable tools.
In order to exercise any of your rights as to personal data controlled by Edge Delta, you may contact us using the contact information at the bottom of this policy. Where legally permitted, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others. As an account owner or a user under a licensed account, you may also take steps to affect your personal data by visiting your account and modifying your personal data directly.
The Website may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. We are not responsible for the privacy policies or the content of such sites.
INFORMATION COLLECTED ON BEHALF OF CUSTOMERS IN PROVIDING OUR PLATFORM
In the case of personal information we handle or receive on behalf of a customer in connection with their access to, and use of, our Platform (“Customer PI”), we have no direct relationship with the customer’s employees or other individuals with whom that customer may interact with respect to the Platform. If you are such an employee or individual and are seeking access to, or would like to correct, amend or delete, Customer PI, you should direct your query to the applicable customer. We will respond within a reasonable timeframe to a customer’s request to remove Customer PI. Please note that the foregoing will not limit EU individuals from making certain requests relating to their personal data as provided below.
We will not use Customer PI except for the purpose of providing and supporting the Services for the applicable customer. Customer PI will be retained for as long as needed for that purpose and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
We take reasonable steps, including physical, technical and organizational measures, to protect your personal information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information submitted to us.
Your personal information will be retained by Edge Delta for the duration of your account and may be retained for a period after this time as necessary and relevant to our legitimate interests, our terms of agreement with you and in accordance with applicable legal obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to enforce the relevant terms of agreement or to identify, issue or resolve legal proceedings.
We may retain a record of your stated objection to the processing of your data, including in respect of an objection to receiving marketing communications, for the sole legitimate purpose of ensuring that we can continue to respect your wishes and not contact you further, during the term of your objection.
EUROPEAN DATA PROTECTION SPECIFIC INFORMATION
DATA SUBJECTS RIGHTS
If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:
Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;
Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;
Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;
Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.
LEGAL BASIS FOR PROCESSING PERSONAL DATA
We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when Edge Delta processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:
As necessary for our contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Edge Delta products, features and services to account owners, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all products, features, and services;
Consistent with specific revocable consents: We rely on your prior consent in order to utilize cookies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage. You have the right to withdraw your consent at any time by visiting our cookie management tool, available Cookies Settings;
As necessary to comply with our legal obligations: We process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) and compliance with privacy laws;
To protect your vital interests or those of others: We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
As necessary for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account owner and/or reseller providing you with the products and services (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our products and services and troubleshoot products and services; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and products and services, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the products and services; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.
INTERNATIONAL DATA TRANSFERS
Edge Delta operates globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected where Edge Delta or its service providers have customers or facilities.
Therefore, by using the Edge Delta Service or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States where we are established, as well as in other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.
CALIFORNIA PRIVACY RIGHTS
CALIFORNIA CONSUMER PRIVACY ACT
Under the California Consumer Privacy Act of 2018 (CCPA), California residents may have a right to:
Access the categories and specific pieces of personal data Edge Delta has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Edge Delta has shared personal data;
Delete personal data under certain circumstances; and
Opt out of the “sale” of personal data. We do not sell your personal data in the conventional sense. However, like many companies, we use advertising services that try to tailor online ads to your interests based on information collected via cookies and similar technologies about your online activity. This is called interest-based advertising. The CCPA’s statutory definition of the term “sale” is broad and may include interest-based advertising.
Edge Delta will not discriminate against you for exercising any of these rights, which is further in line with your rights under the CCPA.
We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to 90 days) in writing.
Under the CCPA, only you or an authorized agent may make a request related to your personal data. Note that to respond to your requests to access or delete personal data under the CCPA, we must verify your identity. We may do so by requiring you to log into your Edge Delta account (if applicable), provide information relating to your account (which will be compared to information we have, such as profile information), give a declaration as to your identity under penalty of perjury, and/or provide additional information. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.
CALIFORNIA’S SHINE THE LIGHT LAW
California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.
This policy is effective as of 14 February 2023.