Privacy Policy

This Privacy Policy was last updated on September 13, 2016.

 

Our Policy:

Welcome to the web site (the “Site”) of Accompani, Inc. (“Accompany”, “we”, “us” and/or “our”). This Site is operated by Accompani, Inc. under the trademark “Accompany” and has been created to provide information about our company and our relationship intelligence platform, mobile applications and related services (together with the Site, the “Services”) to our Service visitors (“you”, “your”). This Privacy Policy sets forth Accompany’s policy with respect to information including personally identifiable data (“Personal Data”) and other information that is collected from visitors to the Site and Services.

 

Definitions:

 

  1. “Person Profile” is a profile about a person that is accessible by every Accompany member. The Person Profile contains news, tweets, bios, employment history and education history, and web links for a specific person. All of the data on a Person Profile is a combination of publicly available information and data that a User input into the profile using Profile Editing. Person Profile does not include Private Editable Fields.
  2. “Private Editable Fields” are fields a User input that are only visible to themselves, such as Notes, Person and Company Notes, Watchlist Slider and manually created contacts. Private Editable Fields are private and visible to a User only.
  3. “Profile Editing” allows you to (after you create an Accompany account) have the option to provide additional information on your Person Profile, or the Person Profile of any other user on Accompany, such as current jobs, past jobs, educational background, bios, profile photos, social profile links, and other information. These changes are visible to every User. Providing additional information enables you to derive more benefit from our Services by finding other professionals, opportunities, and information through our Intros feature; getting more relevant “In Common” results when you view others’ profiles, and getting more relevant person watchlist and company watchlist suggestions. Accompany reserves the right to change or remove any of the information you input through Profile Editing.
  4. “Public Person Profiles” are profiles based on publically available information and created to broaden the Accompany network and resources.
  5. User” means everyone who registered an account with the Services
  6. Your Content” (“Your Data”) means all data (including Personal Data and end user data) that is provided to Accompany by, or on behalf of, a User through a User’s use of the Services, such as:
    1. “Contacts”, which are all of a User’s person contacts imported from third party accounts and a User’s mobile devices, and person contacts provided to Accompany through a User’s use of the Service. This includes social media, email, calendar, mobile, and address book contacts, and any people mentioned in a User’s email and Calendar Events.
    2. “Email Headers”, which include the Header (CC/TO/FROM/Date) fields of your emails.
    3. “Calendar Events”, which are all of your calendar events imported from third party accounts. This includes the meeting title, date/time, location, attendees and description fields, as well as some calendar settings (e.g. alerts, visibility).
    4. Private User Data, which means private electronic data and private information submitted by a User to the Services. This includes notes, insights, family information, username/password, watchlist, and excludes data that a User submitted to public features (e.g. Profile Editing).
  7. “Your Network” consists of the Public Person Profiles that match with your Contacts on Accompany, and a strength indicator of how well you know each of your Contacts. The strength indicator is a proxy score for how well you know someone. You can choose to share Your Network with other users with the Intros feature on Accompany. Your Network does not encompass the private contact information of your Contacts.

Information We Collect:

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:

 

Personal Data That You Provide Through the Services: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services, use certain Services, build profile or account information through the Services, sync your address book or other services to the Services. The Personal Data that you provide to us may collectively or implicitly reveal or identify other things about you that are not expressly stated on your profile (for example, your name or profile picture may reveal your gender). Any Personal Data or other information that you supply to us that may be deemed “sensitive” by applicable law is entirely voluntary on your part. You can withdraw or modify your consent to our use of your Personal Data at any time, in accordance with the terms of this Privacy Policy and our Terms of Service. Wherever Accompany collects Personal Data we make an effort to provide a link to this Privacy Policy.

 

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Accompany and the authorized third parties referred to herein located in the United States.

 

We collect your personal information in the following ways:

  1. Registration. Your account (“Account”) is automatically created when you sign up to our email Services by using the log-in details to your existing email account (i.e. email and password). We collect the additional information you may provide to us during the registration flow (for example, your photo, job title, and company) to match your account with the correct Person Profile, or to create a brand new profile if your identity does not exist in our system.
  2. Email/Calendar Data. When you sign up with your existing email account we collect:
    1. The email address that you used to log into this account; and your basic profile information from that account, such as your full name, title, company and location.
    2. Email Headers. We do not collect or store the text body of your emails or their subject lines.
    3. Calendar Events,
    4. All contacts from your email account, which contain a contact’s full name, email address, social links, homepage link, address, notes about the contact and other fields.
  3. Third Party Account Information. During sign up or through the settings screen after an account has been created, it is possible to connect an Exchange, Outlook.com, Office 365, Google, Facebook, Salesforce or Twitter account to Accompany.
    1. It is possible to unlink all accounts other than the one used for sign up through the settings page.
    2. We do not receive or store your passwords for third party accounts, we only store the username and the authentication token that allows us to access your account to provide the Services. The exception is for Microsoft Exchange, where Microsoft design restrictions require us to store the username/password of your Microsoft Exchange account in order to sync your Accompany account with Microsoft Exchange. For Microsoft Exchange, we use industry standard AES256 bit encryption to securely store your username and password.
    3. We store some of the data from your synced accounts. For email accounts (Outlook.com, Office365, Exchange, Google), we store the fields listed in item II. For social accounts (Facebook, Twitter), please see the “Integrating Social Networking Services” section.
  4. Profile Editing and Private Editable Fields. All data input by a User through the use of Profile Editing and Private Editable Fields is collected and stored.
  5. Location. We collect and store your location, including geolocation, IP based location, beacon based location, and GPS location. You may be able to disallow our use of certain location data through your device or browser settings, for example by disabling “Location Services” for the Accompany application in iOS privacy settings.

 

Other Information:

  • Non-Identifiable Data: When you interact with Accompany through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Accompany may store such information itself or such information may be included in databases owned and maintained by Accompany affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process. In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.
  • Aggregated Personal Data: In an ongoing effort to better understand and serve the Users, Accompany often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Accompany may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Accompany may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

 

Google Analytics: We may allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyze how users use the Site and enhance your experience when you use the Service. For more information on how Google uses this data, go towww.google.com/policies/privacy/partners/.

 

Our Use of Your Personal Data and Other Information:

Accompany uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. Accompany and its subsidiaries and affiliates may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services.

 

Customer Support Visibility:  We realize calendars may hold sensitive information and redact all but the first and last 3 letters of the event title and the entire event descriptions in our customer support interfaces. The first and last 3 letters of the event title are kept so that our customer advocates may serve you on calendar questions.

We are only accessing Email Headers in order to detect communication patterns to serve up more relevant news on Your Network, show you watchlist suggestions and improve your Service experience. You will see Subject lines and snippets of email in Email History. The email body and email subject are generated in real time when you tap on the Email History tab by making API calls to your mail server and are not stored in the Accompany server. Our customer support interface redacts the body and subjects of these emails.

 

Accompany Visibility: Accompany employees, contractors, and agents may, from time to time, access a User’s Personal Data in order to improve the Services. When we do so, we obfuscate the email body, email subject, calendar event name, and calendar event details.

Accompany and its affiliates may use Personal Data to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. We may also send you service and administrative emails, contact you to inform you about changes in our services, our service offerings, and important service related notices, such as changes to this policy or security and fraud notices. These messages are considered part of the service and you may not opt-out of them. If Accompany intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

 

Intros:  Using the Intros feature, you can share Your Network with other users on Accompany and vice versa. To grant another user access to Your Network, you need to grant explicit permission on Accompany. Without your explicit permission, no user has any access or visibility to Your Network. When you share Your Network with another user, that user will be granted access to the Public Person Profiles of all of your contacts and a strength indicator of how well you know each of your contacts. Contact information of Your Network will only be visible to other users if that contact information was already publicly available via the Public Person Profiles. The user with access to Your Network will not have access to

  1. Your Content, except for Your Network
  2. Your Calendar Events
  3. Your Email Content
  4. Your Contacts’ contact information, such as email, phone number, social links, that is not publicly available on Accompany.

 

Our Disclosure of Your Personal Data and Other Information:

Accompany is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

  • Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
  • Agents, Consultants and Related Third Parties. Accompany, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
  • Your Election. We may disclose your Personal Data as elected by you through your use of the profile privacy settings, use of the Intro’s feature or your input of information into public fields.
  • Legal Requirements. Accompany may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Accompany, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

 

Your Choices:

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.

 

Exclusions:

This Privacy Policy does not apply to any Personal Data collected by Accompany other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Accompany through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Accompany shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

 

Children:

Accompany does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Accompany through the Services, please contact us, and we will endeavor to delete that information from our databases.

 

Links to Other Web Sites:

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by Accompany (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Accompany endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

 

Integrating Social Networking Services:

One of the special features of the Service is that it allows you to enable or log in to the Services via various social networking services like Facebook or Twitter (“Social Networking Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Service or log into the Service using your Social Networking Services account, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of such third parties, and Accompany shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Service.

 

You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Twitter that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.

 

Account Deactivation and Data Retention:

You may deactivate or permanently delete your Accompany account by contacting us at support@accompany.com.

 

If you choose to deactivate your account, your account will be inaccessible until you choose to reactivate it. We will retain the information you have created or saved within Accompany. If you do not choose to reactivate your account within 90 days of requesting deactivation, your account may be permanently deleted, and your Notes, Tags, Contact and Company Notes, Favorites, Watchlist, Importance Rankings, or any Private Editable Fields will no longer be available.

 

If you request that Accompany permanently delete your account, you will no longer have access to the information you have created or saved within Accompany. It may take up to 90 days to delete your information from our systems, including your Notes, Contact and Company Notes, Favorites, Watchlist, and Importance Rankings. If you create a new account at a later date, your previous Notes, Contact and Company Notes, Favorites, Watchlist, and Importance Rankings will not be available to you. For technical reasons some information, such as usage and error logs, may be retained in our databases.

 

Security:

Accompany takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

We take the security of Your Data seriously. We use technical and administrative security measures such as, but not limited to, firewalls, encryption techniques, and authentication procedures, among others, to work to maintain the security of your online session and personal information. In particular:

  • Encryption. We encrypt information in storage using 256-bit AES encryption and in transit using 128-bit SSL encryption. In addition, we conduct security audits with a third-party white-hat provide to test our security measures.
  • Disaster Recovery. We implement nightly backups of all databases and our data is stored simultaneously at multiple, geographically distributed locations to ensure redundancy in the event of a natural disaster or other emergency.

However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Accompany via the Internet.

 

Other Terms and Conditions:

Your access to and use of the Services is subject to the Terms of Service at www.accompany.com/tos

 

Changes to Accompany’s Privacy Policy:

The Services and our business may change from time to time. As a result, at times it may be necessary for Accompany to make changes to this Privacy Policy. Accompany reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

 

Access to Information; Contacting Accompany:

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.

Please also feel free to contact us if you have any questions about Accompany’s Privacy Policy or the information practices of the Services.

You may contact us as follows: privacy@accompany.com.