Ankored Privacy Policy

Last Updated: October 18, 2023

 

1. Introduction

 

Ankored, Inc., together with its subsidiaries, affiliates, assignees (“Ankored”, “Company”, “we” or “us”) has adopted this privacy policy (“Privacy Policy”) to demonstrate Ankored’s commitment to protecting your privacy. This Privacy Policy explains (i) what information Ankored collects or that you may provide in connection with the operation of www.ankored.com (“Website”), or through Ankored’s mobile applications or other Ankored services (collectively the “Platform”); (ii) how such information is stored, protected, maintained and used; and (iii) how you can access and correct certain information that we may collect.

The Platform is, respectively, a web-based and a mobile platform for participant safety and compliance, which includes a communication platform between administrators and members for reporting and emergency response. Please note that Ankored is not considered a covered entity as defined in the Health Insurance Portability and Accountability Act (“HIPAA”) and therefore is not required to follow HIPAA.

Please note that this Privacy Policy applies to information we collect from you via the Platform, and information we collect in email, text, and other electronic messages between you and the Platform. This Privacy Policy does not apply to information collected by us offline or through any other website operated by any third party. The Platform may contain advertisements and/or links to third-party websites that are not controlled or operated by us. This Privacy Policy does not apply to such third party websites, and the Company is not responsible for the content of such third-party websites or the privacy practices of such third parties. Therefore, we encourage you to request and review the privacy policies of any third parties upon disclosing your information to such parties or visiting their websites.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you can choose to not use our Platform. We may modify this Privacy Policy at any time. We will notify you of changes within a timely manner using the contact information used for billing purposes or with an announcement of such change on the home page. Your continued use of the Platform is deemed an acceptance of changes to the Privacy Policy, so please review the Privacy Policy periodically. See “Changes to Our Privacy Policy” for more information. Should you not accept our new policy, you should discontinue your use of the Platform.

 

2. Children Under the Age of 13

 

Ankored’s Platform is not intended for use by children under 13 years of age, nor are children the intended audience of the Platform. We do not knowingly collect personal information from children under 13, and all personal information concerning such children is collected from their parent(s) or legal guardian(s). No one under age 13 may provide any personal information to or on the Platform.  If we learn we have collected or received personal information from a child under age 13 without verification of parental consent, we will promptly delete that information. If you believe we might have any information provided by a child under age 13, please contact us at the contact information provided below. Parents and legal guardians are encouraged to discuss online safety with their minor children and to monitor such children’s use of the Internet and mobile applications.

 

3. Information Collected

 

We collect several types of information about you and/or your participant, including:

  • Information by which you may be personally identified;
  • Information that is about you but individually does not identify you; and/or
  • Information about your internet connection, the equipment you use to access our Platform, and usage details.

 

4. How We Collect Information

 

We collect information about you and/or your participant in three ways:

Information You Provide: When you create an account for your participant (the “Ankored Account”) or log into the Platform, you will have the option of providing personally identifiable information about yourself and your child, including the following: name, address, telephone number, facsimile number, email address, year of birth, medical information, user name and password.

Information from Third Parties and Other Sources: Third parties may provide us with information on you and/or your participant, such as details with respect to social media accounts. We may also obtain additional commercially available information from third parties.

Information from Your Use of the Platform: We may collect information about the pages that you visit on the Platform, the content that you provide or view, and how you react to such content. This information includes:

  • Log Information: When you use the Platform, or view content provided in the Platform, we may automatically collect and store certain information in server logs, including with respect to your usage of the Platform, pages you visited, the content you viewed, errors experienced, and the websites you visited before or after you visit the Platform.
  • Location Information: We may collect and process information about your actual location, including from GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.
  • Unique Application Numbers: Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to Ankored when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.

5. User Contributions

 

In the course of your use of the Platform, you will be able to provide additional information, including without limitation, commenting on content appearing on the Platform, communicating with other users of the Platform or uploading content into the Platform.

If you provide information to be published or displayed (hereinafter, "posted") on public areas of the Platform, or transmitted to other users or third parties (collectively, "User Contributions"), these User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

The information we collect automatically may include statistical data, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Platform to deliver a better and more personalized service by enabling us to:

  • Store information about your preferences, allowing us to customize our Platform according to your individual interests;
  • Speed up your searches;
  • Recognize you when you return to our Platform;
  • Estimate our audience size and usage patterns.

6. Cookies and Other Technologies

 

We use various technologies to collect and store information when you use the Platform, and this may include sending one or more cookies or anonymous identifiers to your device, including “web beacons”, clear GIFs, pixel tags and other means. Cookies help us in many ways to make your use of the Platform more enjoyable and meaningful to you. Cookies are text information files that your web browser places on your computer and/or mobile device when you visit a website. Pixel tags are not visible to the user of a website and consist of a few lines of computer coding delivered with the web pages accessed. Ankored may use such technologies to obtain non-personal information from you as an online visitor. You may refuse to accept browser cookies by activating the appropriate setting on your browser. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform. Please note that if you refuse to accept browser cookies, you may not be able to take full advantage of all of the features of the Platform.

 

7. Use of Your Personally Identifiable Information

 

The personally identifiable information that you provide and that we collect will be stored and maintained by Ankored for so long as we believe is necessary or appropriate (i) to carry out the purpose(s) and the use(s) for which such information was collected, or (ii) to comply with applicable laws, contracts, or other rules or regulations.

When you contact Ankored, we may keep a record of your communication to help solve any issues you may be facing.

Upon our collection of your personally identifiable information, Ankored may use such personally identifiable information internally, separately or in combination with pre-existing information, for the purposes set forth below. We will ask for your consent before using information for a purpose other than those that are set forth in this Privacy Policy. We may use your information for the following purposes:

  • To contact you, including via email, for purposes of responding to your comments or requests for information;
  • To contact you with more information about Ankored and its services;
  • To customize your experience on the Platform, including providing you with more relevant products, services or content;
  • To improve our products and services and troubleshoot problems with the Platform, or any services, as requested;
  • To enforce the Terms of Use or this Privacy Policy;
  • To generate aggregated statistical studies and conduct research which may be used in marketing our services to you or to third parties;
  • For marketing and promotional purposes like offering you products or services we recommend;
  • To provide any legitimate business service or product.

We may also collect other materials shared for your application to a job or role through Ankored or in connection with a job or role where Ankored serves you, an employer for that job, or other organization for that role. Such other materials may include (but is not limited to) background checks, employment checks, driving records, professional license and certification checks, and identity verifications. Ankored processes your personal data and may store your personal data on behalf of you, an employer, or other organization. Ankored processes your personal data in facilitation of your application progress, an employment requirement, and/or an organization’s participation requirements, as well as to aid employers and/or organizations searching for candidates for certain jobs or roles, respectively. Your personal data may be retained for the life of your account with Ankored and may be preserved for longer based on your interactions with any employer or organization through Ankored or as required by law. Moreover, Ankored may share your personal data with or transfer your personal data to:

  • Our own affiliates to improve our services (such as by providing you with personalized and improved content, performance, features and service);
  • Employers (including their affiliates), including on the instruction of you or employers using Ankored services, in the course of job searches, applications, interviewing, and during employer-employee relationships. Sharing or transfers may include sending data to other platforms processing your personally identifiable information such as an employer’s applicant tracking system (ATS), customer relationship management (CRM) system, human resources (HR) system, or other software system;
  • Organizations (including their affiliates), including on the instruction of you or organizations using Ankored services, in the course of finding persons for organizational roles or organizational activities (e.g., a sports organization with coaching roles). Sharing or transfers may include sending data to other platforms processing your personally identifiable information such as an organization’s ATS, CRM system, HR system, or other software system;
  • Service providers and other third parties to perform services on our behalf in connection with Ankored’s operations, to improve the Ankored Platform and to improve Ankored’s services.

Certain sensitive personal data or special categories of data (e.g., demographic data such as age, disability, and criminal history) is only collected where permissible by law and is only collected with your consent.

Your consent may be collected, and you may express your consent, by a variety of actions. For example, we may display a brief notice and your check of a box constitutes consent. Consent may be expressed by completing a form or by providing your personal information after being prompted to do so or in order to continue with your activity on the Platform, such as uploading material or completing other information collection requirements.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may combine personal information about you received from several sources, including without limitation, the information described above under “Information from Third Parties and Other Sources” and “Information from Your Use of the Website” in order to create more tailored, personalized promotions of certain products and services for you and to better market our products and services to you and to third parties. We may share such personal information, in an aggregated non-personally identifiable manner with third parties. When showing or providing you with tailored content, we will not associate a cookie or anonymous identifier with sensitive categories, such as those based on race, religion, sexual orientation or health.

 

8. Data Sharing and Transfer

 

Ankored will not trade, sell or share your personal information for use by any third party except in the following circumstances:

  • With Your Consent, which includes organizations, entities or persons you authorize when establishing or registering your account or third parties that provide training or certification or similar services through the Platform that you elect to engage with or from whom you purchase services;
  • With Your Third-Party Service Providers – If your Ankored Account is managed for you by a third party service provider then such service providers will have access to your Ankored Account information (including your email and other data);
  • For External Processing. We may provide your personal information with your consent to our affiliates and other trusted businesses or persons that provide services to us in connection with our business activities, based on our instructions and in compliance with this Privacy Policy and under binding contractual obligations of confidentiality and security. These third parties are authorized to use your personal information only as necessary to provide such services to us;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ankored's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Ankored about our Website users is among the assets transferred; and
  • To fulfill the purposes for which you provide it.
  • As Required by Law or for the Protection of Rights. Ankored reserves the right to disclose your personally identifiable information based on its good faith belief that such action is necessary or appropriate to: (a) meet any applicable law, regulation, legal process or enforceable governmental request; (b) enforce the Terms of Use or this Privacy Policy, including investigation of potential violations; (c) detect, prevent, or otherwise address fraud, security or technical issues; (d) protect and defend the rights or property of Ankored: or (e) act in urgent circumstances to protect the safety or security of the public or of users of Ankored’s services, the Platform.

Notwithstanding the foregoing, we may share aggregated, non-personally identifiable information, publicly and with companies or financial institutions that perform marketing services on our behalf or with other financial institutions with which we have joint marketing arrangements. For example, we may share information publicly to show trends about the general use of our services.

We may sell such aggregated, non-personally identifiable information to third parties.

We may combine information collected about you, and share it, in an aggregated, non-personally identifiable manner, with third parties.

In the event that Ankored is involved in a transaction such as a merger, stock purchase, bankruptcy or sale of substantially all of its assets, your personal information may be transferred to the other party or parties in such transaction. You will be notified via email or notice through the Platform of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

 

9. Security

 

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Data transmitted via the Platform may use a Secure Sockets Layer (SSL) protocol, and data may be encrypted on some pages of the Platform To the extent such technology is utilized on a given page, you may be unable to use certain account or customization features of the Platform unless your web browser software supports SSL encryption.

Your personal information will generally be stored on behalf of Ankored by Azure or similar third-party service providers and will be granted the protections and will be subject to the security procedures utilized by such service provider, whose data protection and privacy protections may not afford the same level of protection as required by laws of certain countries, such as the member nations of the European Union. If you wish to receive information about such third party service providers, you may make such request using use the contact information set forth at the end of this document, including the phrase “Third Party Service Providers” in the subject line, and providing us with your name, address and email address. We will respond to you within-thirty days of receiving such a request. We make no claims that the Platform, or any of their respective contents are appropriate or may be downloaded or accessed outside of the United States. If you access the Platform from outside the United States, you do so at your own risk and are responsible for compliance with the laws of your country. You may not use or export any content of the Platform in violation of U.S. export laws and regulations.

Please note that the servers containing your information may become accessible in the event of a security breach. Also, transmissions of information via the Internet and mobile networks are never completely private or secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. You understand that any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform. If you have any questions about the security of personally identifiable information collected by Ankored, please contact us at the e-mail address shown below.

 

10. Access to your Information

 

We attempt to keep your files complete, up-to-date, and accurate. We tell you how and where to conveniently access your personal information and how to notify us about errors. We offer several ways for you to access and/or update the personal information in the Ankored Account:

You may use the contact information set forth at the end of this document to contact us for any inquiry or request regarding our privacy policy or the handling of your personal information and/or that of your child.

You may log in to the Website and enter any new information about yourself and/or your child.

You also may write to us directly if you wish to: (a) update or delete your personally identifiable information; (b) close your account; (c) request that we cease sending you promotional or other information via mail or e-mail; or (d) request that we cease any further use or future online collection of personal information from your child. Such written requests should be sent to Ankored at the address below. We will comply with requests for the deletion of information subject to the provisions of Section 8 below.

We reserve the right to deny access to personally identifiable information in your Ankored Account (a) when such denial of access is required by law.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices. Please refer to the state privacy rights for those states for more information.

 

11. Your State Privacy Rights

 

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents' privacy rights, visit cppa.ca.gov. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to or write us at the address set forth at the end of this document.

 

12. Choice and Opt Out Preference; Termination

If, at any time, you prefer not to receive further e-mail communications from Ankored, you will have the ability to unsubscribe from all of some of such communications by updating your preferences in your Ankored Account or to contact us to opt out at the contact information below. If, at any time, you prefer not to receive any other form of communication from Ankored, you will have the ability to unsubscribe from such communications or close your Ankored Account by contacting us at the contact information provided below.

If you wish to cancel your Ankored Account or request that we no longer use your information to provide you services, contact us at the contact information provided below.

We will retain your information for as long as your Ankored Account is active or as needed to provide you services or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

13. Do Not Track

 

Ankored does not at this time apply Do Not Track (“DNT’) with respect to your usage of the Website. DNT is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit donottrack.us.

 

14. Questions or Comments

 

Ankored welcomes questions and comments about this Privacy Policy and/or our use of children’s information. Questions or comments should be directed to:

Ankored, Inc.
Attn: Evan Hunt
1660 Soldiers Field Rd STE 7 #1006
Brighton, MA 02135