Your privacy is important to Us and We want to make sure you understand how your data may be collected and used, the steps We take to protect your privacy, and what choices you have with respect to your information. "We", "Our" and "Us" refers to Lean Sensory Systems, Inc., doing business as DraughtLab.
This Privacy Policy applies to Our online tools and mobile applications (collectively, the "Services"), learning.draughtlab.com and other DraughtLab Learning websites (collectively, the "Websites") and other interactions (e.g., customer service inquiries, newsletters, etc.) you may have with DraughtLab Learning. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of DraughtLab Learning's business.
This Privacy Policy does not apply to information collected by Us offline or through any means other than the Services. Additionally, this Privacy Policy does not apply to any third-party applications or software ("Third-party Services") that may link to or be accessible from the Services or the Websites, or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the "Customer Agreement"), including the processing of any event data, images, photos, messages, reviews, folders, data, text and other types of works submitted through Services accounts (collectively, "Customer Content").
The group (your employer or another entity or person) that entered into the Customer Agreement (a "Customer") controls their and their Authorized Users' use of the Services and any associated Customer Content through the Organization. If you have any questions about specific Organization settings and privacy practices, please contact the Customer whose Organization you use.
We may collect and receive Customer Content and other information and data ("Other Information") in a variety of ways:
Customer Content: Customers or individuals granted access to an Organization by a Customer ("Authorized Users") routinely submit Customer Content to Us when using the Services.
Other Information: We also collect, generate and/or receive Other Information:
Organization and Account Information: To create or update an Organization account, the Customer (e.g., your employer) or the Authorized User, as the case may be, supply Us with an email address, phone number, address, password and/or similar account details. In addition, Customers that purchase a paid subscription to the Services provide Us (or Our payment processors) with billing details such as credit card information, banking information and/or a billing address.
Usage Information:
Services Metadata: When a Customer or Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, We log the organizations, features, content, search queries, and links they interact with.
Log Data: As with most websites and technology services delivered over the Internet, Our servers automatically collect information when you access or use Our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
Device Information: We collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application Ids, unique device identifiers and crash data ("Other Information"). Whether We collect some or all of this Other Information often depends on the type of device used and its settings.
Location Information: We receive information from Customers or their Authorized Users and other third parties that helps Us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. We may also collect location information from devices in accordance with the consent process provided by your device.
Cookie Information: A cookie is a small text file sent by Us to your computer or mobile device. Some cookies are associated with your account and personal information in order to remember that you are logged in and which Organization you are logged into. Other cookies are not tied to your account but are unique and allow Us to carry out analytics and customization, among other similar things. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Services, or certain parts of the Services may not function properly. Unless you have adjusted your browser setting so that it will refuse cookies, Our system will issue cookies when you direct your browser to one of Our websites. For more details about how We use these technologies, and your opt-out opportunities and other options, please see Our Cookie Policy.
Generally, no one is under a statutory or contractual obligation to provide any Customer Content or Other Information (collectively, "Information"). However, certain Information is collected automatically and, if some Information, such as Organization setup details is not provided, We may be unable to provide the Services.
Customer Content will be used by Us in accordance with Customer's instructions, including any applicable terms in the Customer Agreement and based on the included functionality of the Customer's purchased plan, and as required by applicable law.
We use Other Information in furtherance of Our legitimate interests in operating Our Services, Websites and business. More specifically, We use Other Information:
To provide, update, maintain and protect Our Services, Websites and business: This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User's request.
As required by applicable law, legal process or regulation:
To communicate with you by responding to your requests, comments and questions. If you contact Us, We may use your Other Information to respond.
To develop and provide additional tools and additional features: We try to make the Services as useful as possible for any specific Organization and all of its Authorized Users. We may look at Service usage and trends to improve the Service or create new features and products.
To send emails and other communications: We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in Our Services, Our Services offerings, and important Services-related notices. These communications are considered part of the Services and you may not opt out of them. In addition, We sometimes send emails about new product features, promotional communications or other news about Us. These are marketing messages so you can control whether you receive them.
For billing, account management and other administrative matters: We may need to contact you for invoicing, account management and similar reasons and We use account data to administer accounts and keep track of billing and payments.
To fulfill any other purpose for which you provide it: We may use information you provide in the way We describe when you provide the information and consent to the use.
To investigate and help prevent security issues and abuse
If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, We may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as "Personal Data."
We will retain data collected through a Customer and it's Authorized Users ("Customer Data") pursuant to the Customer Agreement, in accordance with a Customer's instructions, based on the included functionality of the Customer's purchased plan and as required by applicable law. The deletion of Customer Data and other use of the Services by a Customer may result in the deletion and/or de-identification of certain associated Other Information. We may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce Our agreements.
This section describes how We may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and We do not control how they choose to share or disclose Information.
Customer's Instructions: We will solely share and disclose Customer Data in accordance with a Customer's instructions, including any applicable terms in the Customer Agreement, based on the included functionality of the Customer's purchased plan and in compliance with applicable law and legal process.
Displaying the Services: When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same Organization. For example, an Authorized User's email address may be displayed with their Organization profile.
Customer Access: Owners, administrators, Authorized Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, your employer using the Service to export logs of Organization activity or accessing or modifying your profile details.
Third-party Service Providers and Partners: We may engage third-party companies or individuals as service providers or business partners to process Other Information and support Our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors We use to support delivery of Our Services is set forth in DraughtLab Learning Subprocessors.
Corporate Affiliates: We may share Other Information with Our corporate affiliates, parents and/or subsidiaries (if any).
During a Change to DraughtLab Learning's Business: If We engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Our assets or stock, financing, public offering of securities, acquisition of all or a portion of Our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or De-identified Data: We may disclose or use aggregated or de-identified Other Information for any purpose. For example, We may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective customer the average amount of time spent to complete a Taste Panel within a typical Organization.
To Comply with Laws: If We receive a request for information, We may disclose Other Information if We reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. Please see the DraughtLab Learning Data Request Policy to understand how We respond to requests to disclose data from government agencies and other sources.
To enforce Our rights, prevent fraud, and for safety: To protect and defend the rights, property or safety of Us or a third-party, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
With Consent: We may share Other Information with third parties when We have consent to do so.
We take security of data very seriously. We work hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. Given the nature of communications and information processing technology, We cannot guarantee that Information will be absolutely safe from intrusion by others during transmission through the Internet or while stored on Our systems or otherwise in Our care.
We do not allow use of Our Services and Websites by anyone younger than the age of sixteen (16) or the age of majority, whichever is older. If you learn that anyone younger than sixteen (16) or the age of majority, as applicable, has unlawfully provided Us with personal data, please contact Us and We will take steps to delete such information.
We may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or We may make changes to Our business. If We make changes that materially alter your privacy rights, We will provide notice to you via email or through messaging on the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Please contact the Customer if you wish to request the removal of Personal Data under their control.
Please also feel free to contact Us if you have any questions about this Privacy Policy or Our practices, or if you are seeking to exercise any of your statutory rights. You may contact Us at info@draughtlab.com or at Our mailing address below:
DraughtLab
PO Box 585
Webster, NY 14580-0585
United States