PRIVACY POLICY
Last Revised: October 2, 2024
This privacy notice (the “Privacy Notice”) together
with the Terms of Use constitutes an agreement between you and Cronometer Software Inc. and its affiliates
(collectively
“Cronometer”, “us”, “our,” or “we”) while accessing and using our website located at cronometer.com, other websites we own or
operate, and/or Cronometer’s mobile applications (collectively, the “Site”). This Privacy Notice describes how Cronometer
collects, protects, uses, and discloses information and data collected and created in the course of your access to and use of
the Cronometer website, products, and services, as well as your interactions with Cronometer via telephone, electronic or other
means (collectively, and together with the Site, the “Services”), and is governed by our Terms of Use.
Your privacy is
important, and we encourage you to read this Privacy Notice carefully to understand the information we collect and what we do
with it.
Consent. By accessing the Site, registering with Cronometer, creating a user profile on our
Site, or submitting information to Cronometer, you consent to this Privacy Notice and the collection and use of information as
described below. We will take steps to notify you and confirm that you agree at different stages of collecting information. If
you do not agree with our policies and practices, you may not be able to access or benefit from certain portions of the Site.
Scope. Please be advised that this Privacy Notice applies to information that we collect when you
visit the Site or use our Services, when you submit your information to us on the Site or our Services, when you communicate
with us through email and other means, via third parties that we work with to provide our Services, or by any other means over
the course of your use of our Services.
For purposes of this Privacy Notice:
“HIPAA” means
the United States Health Insurance Portability and Accountability Act of 1996.
“PHI” means
individually identifiable health information, held or maintained by a Covered Entity or its Business Associates acting for the
Covered Entity that is transmitted or maintained in any form or medium (including the PHI of non-U.S. citizens).
“Business Associate” means a person or entity that performs certain functions or activities that
involve the use or disclosure of PHI on behalf of, or provides services to, a HIPAA Covered Entity.
“Covered
Entity” means (1) health plans, (2) health care clearinghouses, and (3) health care providers who electronically
transmit any health information in connection with transactions to which HIPAA applies.
“Content” means
any expression fixed in a tangible medium and includes, without limitation, ideas, text, comments, video, audio, graphics,
designs, drawings, animations, logos, trademarks, copyrights, information, data, software, scripts, executable files, recipes,
workouts, likes, activities, maps, routes, nutritional information and data, and any intellectual property therein, any of which
may be created, submitted, or otherwise made accessible on or through the Site and/or Services.
Personal
Information. As used in this Privacy Notice, “Personal Information” means information that identifies, relates to,
describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a
particular individual consumer, account or device, such as:
Non Personal Information. As used in this Privacy Notice, “Non-Personal Information” means
information that does not identify you and cannot be used to contact you personally and may include: (a) certain publicly
available information; (b) aggregate information, meaning data about a group or category of services or users from which
individual identities and other Personal Information has been removed; (c) deidentified information that cannot be easily linked
back to the individual; or (d) and in full compliance with HIPAA and Privacy laws, and on an aggregated and anonymous basis,
your diary entries, health data, recipes, targets and profile. Under certain circumstances, Personal Information and/or
Non-Personal Information may constitute PHI. If HIPAA applies to such Personal Information and/or Non-Personal Information, we
will take appropriate steps to comply with HIPAA’s privacy and security rule requirement. For example, if we are a Business
Associate of a Covered Entity, and if specific Personal Information and/or Non-Personal Information that we use or disclose as
such a Business Associate is PHI, we will take appropriate steps to comply with HIPAA’s privacy and security rule requirement
with respect to any such use and disclosure.
Lawful Basis. We will only collect your Personal
Information (a) when applicable, with your consent; or (b) as authorized or required by law. We will limit the collection of
Personal Information to that which is reasonable. If we collect or use your Personal Information based on your consent, we will
also notify you of any changes and will request your further consent as needed.
HOW WE COLLECT & USE YOUR
PERSONAL INFORMATION The Personal Information we collect about you and how we use the Personal Information we
collect depends on the context of your interactions with Cronometer, the Site, and our Services.
Information we
collect directly from you, with your consent. We collect Personal Information directly from you with your consent
when you leave a comment or use other interactive features on the Site or communicate with us online or by other means. If you
leave a comment on the Site, we collect your email address and IP address to confirm that the comment originated from a Site
user and not from a bot or other automated spam generator. If you access or submit an inquiry through our Site, subscribe to a
service, register to receive marketing materials, participate in contests, sweepstakes or promotions, or receive other Services,
we may ask you to provide certain personal information such as your name, email address, phone number and zip code, and possibly
other Personal Information. We take reasonable steps to make sure that your contact information is accurate, complete, current,
and otherwise reliable. We use your Personal Information to communicate with you about Cronometer and our Services and for
direct marketing purposes, such as:
We will only contact you in ways compatible with your communications choices. However, even if you have
opted-out of receiving marketing communications from us, we may need to contact you to address questions or issues specific to
the services you have requested.
We may periodically supplement the Personal Information we collect from you with
personal or non-personal information about you or another person obtained from companies with whom we have marketing or other
business relationships and other third party sources. Any aggregate information that is linked or linkable to your Personal
Information will be treated as Personal Information under this Privacy Notice.
Currently, Cronometer or our third party
service providers retain and store information collected by, or provided to, us in the cloud and on secure, HIPAA compliant
servers in the United States. As Cronometer and some of our third party service providers may retain and store information
received from users (including Personal Information) outside of Canada, and under the laws of those other jurisdictions, in
certain circumstances courts, law enforcement agencies, regulatory agencies or security authorities in those other provinces or
foreign jurisdictions may be entitled to access users’ information.
Payment Information. Cronometer
does not collect or maintain any payment information. If you choose to subscribe to our Site and/or Services, our current
payment processor, will collect your financial information to facilitate the transaction. We partner with third party service
providers and vendors to provide access to existing payment gateways and your credit card, banking and other billing information
will be stored only with our payment processor, not with Cronometer. You will be given information regarding our current payment
processor, including access to their privacy policy and terms, when you authorize a transaction through the Site.
Information collected from your use of the Site, with a legitimate interest. We use analytics tools
or other technologies to collect information about you from your use of this Site. We collect this information to achieve our
legitimate interests of operating the Site and our Service, as well as marketing our Services to a broader audience. This
information may be combined with other information that you choose to submit to us. This information may also be merged into
aggregate information about site visitors and traffic. We use third-party analytics tools to distinguish and analyze user
behavior.
Log Files. We collect anonymous and technical information from your computer, including your internet
protocol address, data about your computer or other device, the type of browser or operating system your device uses, the
programs, services, and version of software you use, and the address of any linking site, when you request a web page while
visiting the Site. We use this information for statistical purposes, to ensure that our web pages will appear and function
appropriately on your computer, to determine how you were referred to our Site, and to personalize your access to our Site or
conduct our own analyses and research to improve our programs, products, services, and content. We may sell, rent, or otherwise
convey this anonymous, technical information to a third party, but this information will never constitute Personal Information.
We also use third parties to collect and analyze information. If you do not agree with Cronometer or our Services Providers (as
defined below) collecting and using your anonymous and technical information as described in this paragraph, discontinue use of
the Site or you may contact us as described under “Controlling Your Personal Information.”
Cookies. Like most
commercial websites, we use cookies to track use of our Site. Cookies are small text files that are stored on your computer or
equipment when you visit certain online pages that record your preferences. Cronometer and our Service Providers use cookies to
track use of our Site and online services. Cookies may also be used to monitor traffic, improve the Site, make the Site easier
and/or more relevant for your use, and improve the performance of our advertising. You can make personalized choices regarding
the cookies employed within the Site in the Settings section. However, certain features of our Sites or other Services may not
work if you delete or disable cookies. For more information on cookies and how to disable them on your computer please visit: https://www.consumer.ftc.gov/articles/0042-online-tracking.
Generally-speaking, we use 1st and 3rd-party session and persistent cookies. The cookies set by us are called
“1st-party cookies” and the cookies set by our Service Providers are called “3rd-party cookies.” Session cookies are temporary
cookies that remain on your device until you close your web browser. Many session cookies are essential to make our Site work
correctly, as they typically enable you to move around our Site and use our features. Persistent cookies remain on your device
after you close your browser or until you manually delete it (for the former, the amount of time the cookie remains on your
device will depend on the duration or “lifetime” of the specific cookie and your browser settings). Persistent cookies help us
recognize you as an existing user of our Site, so it’s easier and convenient to return to our Site or interact with our Services
without signing in again. In addition, persistent cookies also help us recognize you when you view a resource belonging to our
Site from another website or app (such as an advertisement) and help us record information about your web browsing habits during
the lifetime of the persistent cookie.
Examples of cookies we use:
Information we collect indirectly from you, with your consent. We collect Personal
Information from other sources with your consent, such as health applications on your device. For example, in such cases, we
adhere to the following:
There may be other instances where we collect Personal Information from other sources, such as third-party
applications, with your consent. In these cases, we will only do so after receiving your express consent to access the data and
will do so in compliance with any applicable terms, the third-party privacy policy and this Privacy Notice.
Cronometer
uses Personal Information collected from you automatically perform data analysis, identify Site and Services usage trends,
develop and display content and advertising tailored to your interests or location, and to measure the effectiveness of our
marketing efforts and our Services. Cronometer may use and store this information and the reports we generate using this
information in an anonymized form or in the aggregate that it is not associated with individual end users and does not include
personal information.
Other ways we might use your Personal Information. In addition to the specific
uses and purposes described above, we might use information that we collect about you or that you provide to us, including any
Personal Information:
Children Under Age 16. Cronometer products and services are designed to benefit both adults
and children. However, any Personal Information submitted pertaining to children under the age of 16 must be explicitly
consented to by that child’s parent or legal guardian. As such, this Site may not be used, and no Personal Information should be
submitted from children under 16 years of age without such consent. If you are under 16, do not use or provide any information
on this Site or on or through any of its features, make any purchases through the Site, use any of the interactive or public
comment features of the Site or provide any information about yourself to us, including your name, address, telephone number,
email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from
a child under 16 without verification of parental or legal guardian consent, we will delete that information. If you believe we
might have any information from or about a child under 16 without appropriate consent from a legal guardian, please contact us
at privacy@cronometer.com.
A
SPECIAL
NOTE ABOUT YOUR HEALTH INFORMATION
We are committed to protecting your privacy and we recognize the
sensitivity of your health information. We will manage your PHI in accordance with applicable health information privacy
legislation, such as HIPAA.
We do not sell PHI, or provide it to third parties without your consent.
You
should consider carefully the nature of the sensitive health information you add to your account. As noted below, we take
reasonable, legally permitted measures to protect your information from law enforcement, however, it may be subject to access in
accordance with applicable laws.
In some cases, healthcare providers may be using our Services to collect, use and
disclose personal information about you, their patient. As applicable, those healthcare providers are the custodians of that
personal health information. If you would like to know more about how your healthcare provider handles your personal
information, you should ask them about their policies and practices.
DISCLOSURE OF YOUR INFORMATION
As permitted by applicable law, we may share your Personal Information as follows:
SECURITY
Data Security. It is Cronometer’s policy to treat your
Personal Information with complete confidentiality. We minimize the Personal Information we store and employ commercially
appropriate and reasonable safeguards both online and offline to maintain the security, confidentiality, and integrity of
information that we collect about you. We maintain physical, electronic and procedural security measures to safeguard your
non-public personal information. We update and test our technology to improve the protection of our information about you and to
assure the integrity of that information.
We educate our employees about the importance of confidentiality and customer
privacy through standard operating procedures and special training programs.
In many instances we employ
state-of-the-art, and in any event commercially reasonable, measures to protect your Personal Information, such as two-factor
authentication, penetration testing, the implementation of privacy-by-design and thorough vetting of our hosting services
providers. However, please note, however, that no transmission of data over the internet is 100% secure and we cannot guarantee
that unauthorized third parties will not defeat those measures and use nonpublic Personal Information for improper purposes.
Therefore, we are not responsible for circumvention of any privacy settings or security measures contained on the Site or for
actions of third parties. The safety and security of your information also depends on you, and you are responsible for keeping
your password confidential. Also, always remember to log off your account and close your browser window when you have finished
your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else
or are using a computer in a public place. Please refer to the Federal Trade Commission's website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for
information about how to help protect yourself against identity theft.
Public Forums. If you choose
to make use of any public forum, comment section or chat function, we may collect any information you may disclose through such
means.
In-Media Communications. If you choose to send a message to another user or defined group of
users through our message, chat, post or other function, we may collect any information you may disclose through such means, as
well as the necessary Personal Information of the user(s) you are contacting, in order to facilitate the communication.
Third Party Sites. This Privacy Notice applies only to information collected by Cronometer. We may
provide links to third party websites from our Sites as a service to our users, but we have no ability to control, and we are
not responsible for, the privacy and data collection, use, and disclosure practices of third party websites. When you click on
links that take you to external websites, you will be subject to their privacy policies and practices and not ours. We encourage
you to review and understand the privacy policies of such websites before providing them with any information.
Photos and Videos. If you post a video, image or photo on our Site for public view you should be
aware that these may be viewed, collected, copied and/or used by other users without your knowledge or consent. We are not
responsible for the videos, or photos that you choose to submit to the public sections of our Site. For clarity, there are also
private sections of the Site where you can submit content that will not be viewable by other users. Please see our Terms of
Service at https://cronometer.com/terms/ on this point and for
other
guidelines about posting content on any portion of our Site.
Updates and Push Notifications. We may
occasionally send you updates, patches and related push notifications that may be of importance to you. If you do not wish to
receive updates, patches and notifications you should discontinue use of our Site and/or Services or disconnect your computer or
device from the Internet. If you do not wish to receive push notifications, do not select the "Send me newsletters and
promotional emails" box under your Account Information in your Cronometer Profile. If you choose to enable push
notifications, we may use your information such as a device ID or email address in order to send push notifications to your
device.
Do Not Track Signals. Do Not Track is a privacy preference that users can set in their web
browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the
user. For information about Do Not Track, visit www.allaboutdnt.org. At
this time, Cronometer
does not respond to Do Not Track browser settings or signals. In addition, Cronometer may use other technology that is standard
to the internet to track visitors to the Site. Those tools may be used by us and by third parties to collect information about
you and your internet activity, even if you have turned on the Do Not Track signal.
Unauthorized Use. If
you become aware of any unauthorized submission of information to Cronometer, including children’s information, please inform us
by contacting us at the contact information listed below so that we may delete it.
RETAINING AND DELETING YOUR
PERSONAL INFORMATION
Cronometer retains Personal Information as long as it is reasonably necessary to
provide the Services to you and others such as professionals on your behalf. This includes consideration of business
requirements and legal obligations to retain the information. You have the ability to delete information from your account at
any time.
As described in the “Controlling your Personal Information” section below, you can control many aspects of
the information in your account, such as profile information, including by deleting the information or your account. As
described below, you may request deletion of your account by making a request to privacy@cronometer.com.
Otherwise, we will generally keep information associated with your account until it is no longer reasonably necessary to
provide the Services, or until your account is deleted. We may delete accounts that are unused for a certain period, such as no
activity for 36 months, depending on the nature of the account. We may consider the amount, nature and sensitivity of the
personal information and purposes for which it may be processed to determine retention. We may retain de-identified or
aggregated information with other non-personal data indefinitely as it is no longer Personal Information and it may be useful
for our business purposes.
Following the deletion of information from your account, your account, or a request for
deletion, we take steps to fully delete the Personal Information from our logs and systems within a reasonable time. We may
retain information for a longer period as permitted by law, including for legal compliance and regulatory purposes, to prevent
fraud, collect fees, resolve disputes, assist with investigations, or enforce our terms or a legal right. We will handle the
information we retain in accordance with this Privacy Notice.
CONTROLLING YOUR PERSONAL
INFORMATION
Cronometer provides you the ability to exercise certain controls and choices regarding our
collection, use and sharing of your information. Depending on where you reside, your options to control your Personal
Information may include some or all of the following:
At any time, you may exercise any of these controls and choices, express concerns, lodge a complaint, or
obtain additional information about the use of your Personal Information by contacting us at privacy@cronometer.com.
We Do
Not
Sell Your Personal Information. Cronometer will not share the details of your Cronometer account for commercial
purposes without the express permission of the end-user, and in accordance with all relevant legislation.
Opting
Out of Sharing. We may share your Personal Information with friends and professionals, for example, as permitted
by you. If you would like to opt-out of sharing your Personal Information, there are various ways you can accomplish this. You
may delete your account at any time, following which, we will not share your information with third parties except as may be
required by law. You may also see and control sharing with third parties through your account by going to the “More” link and
selecting “Sharing” in your account. You will be able to see the friends you are sharing with (for Gold subscribers), as well
as the professionals and third party apps which you have connected to your account. You may decide to add or stop sharing with
any apps or professionals. If you would like to opt-out of sharing in these ways, or opt-out of sharing any targeted
advertising, sharing with third-parties, please contact our privacy officer at privacy@cronometer.com.
In some circumstances, opting out of sharing may mean we or third parties are not able to provide you with certain services. We
may also consider certain legal, contractual and business interests and obligations and your rights, including to opt-out in the
circumstances.
Opting Out of Communications. We will only communicate with you if you want to hear
from us, or if it necessitated by the Services you receive from us (i.e. transactional, payment or invoicing related messages).
You can modify or limit the communications we send to you by clicking the “unsubscribe” link at the bottom of any of our emails,
or by visiting the “Settings” section of the Site where you can make specific choices regarding your communication preferences.
You may also contact us directly by email at privacy@cronometer.com.
Please be sure to include your full name, email address and specifically what information you do not want to
receive.
UNITED STATES – STATE PRIVACY LAWS
This section of the Privacy Policy is specifically
intended to address Cronometer’s obligations in respect of the various states with privacy laws, including California, Colorado,
Connecticut, Montana, Oregon, Texas, Virginia, and Utah. Along with the provisions above, the sections below describes
additional measures we take to collect, use, and share personal data in accordance with the respective state laws.
CALIFORNIA PRIVACY RIGHTS
Cronometer adopted this section to comply with the California
Consumer Privacy Act (“CCPA”) and applies to residents of the State of California (“California Consumers”). Without limiting the
foregoing, this section provides California Consumers with the disclosures and notices required under the CCPA. Certain
exceptions and limitations, may apply to a California Consumer’s rights and Cronometer’s obligations under the CCPA.
Personal Information Collected. Cronometer has collected the following categories of Personal
Information from California Consumers within the last twelve (12) months:
Sources for the Personal Information We Collect. We collect the Personal Information described above from the following sources:
Use of Personal Information. Depending on your interactions with Cronometer, we may use or
disclose the Personal Information we collect about you for one or more of the following business purposes:
We will not collect additional categories of Personal Information or use the Personal Information we collect
for materially different, unrelated, or incompatible purposes without notifying you.
Disclosing Personal
Information. Cronometer may disclose Personal Information for a business purpose to the following categories of
third parties:
In the preceding twelve (12) months, Cronometer has disclosed the following categories of Personal
Information for a business purpose:
No Sale of Personal Information. Cronometer has not sold any Personal Information in the
preceding twelve (12) months.
Your Rights and Choices. The CCPA provides California Consumers with
specific rights regarding their Personal Information. The following paragraphs describe CCPA rights and explain how to exercise
those rights. Each of these rights is subject to our receipt of a verifiable consumer request (see below).
Right
to Disclosure. You have the right to request that we disclose certain information to you about our collection and
use of your Personal Information over the past 12 months, such as:
Cronometer is only required to respond to two disclosure requests within a 12-month period.
Right
to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we
have collected about you over the past 12 months (also called a data portability request). If you submit a right to access
request, we will provide you with copies of the requested pieces of Personal Information in a portable and readily usable
format. Please note that Cronometer is prohibited by law from disclosing copies of certain pieces of Personal Information (e.g.,
government identification numbers, financial account information, and passwords or security questions and answers) because the
disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our business
systems, or your account. Cronometer is only required by law to respond to two access requests within a 12-month period.
Right to Deletion. You have the right to request that we delete any of your Personal Information that
we collected from you and retained, with certain exceptions. Cronometer may permanently delete, deidentify, or aggregate the
Personal Information in response to a request for deletion. If you submit a right to deletion request, we will confirm the
Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.
Submit a Consumer Privacy Request. To exercise any of the above rights, please submit a verifiable
consumer privacy request to Cronometer by email at privacy@cronometer.com.
Verification. We
cannot respond to your request or provide you with Personal Information unless we can verify your identity and your authority to
make the request and confirm that the Personal Information relates to you. A verifiable consumer privacy request must:
You do not have to sign up with Cronometer to make a verifiable consumer privacy request. We will only use Personal Information
provided in a verifiable consumer privacy request to verify the requestor’s identity or authority to make the request.
Authorized
Agent. You may make a verifiable consumer request on behalf of your minor child. Otherwise, only you, or a person
you have designated in writing as your authorized agent or who is registered with the California Secretary of State to act on
your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465
(“Authorized Agent”) may make a verifiable consumer request related to your Personal Information. If you wish to have an
Authorized Agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof
that you have designated them as your Authorized Agent, and we will still require you to provide sufficient information to allow
us to reasonably verify that you are the person about whom we collected Personal Information.
Cronometer’s
Response. We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more
time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or
electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the
verifiable consumer request. If we cannot comply with part or all of your request, we will explain the reasons in our response.
We do not charge a fee to process or respond to your verifiable consumer privacy request unless it is excessive, repetitive, or
manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide
you with a cost estimate before completing your request.
Nondiscrimination. We will not discriminate
against you for exercising any of your CCPA rights.
Unless permitted by law, we will not do any of the following as a
result of your having exercised your right under the CCPA:
Other California Privacy Rights. California Civil Code sections 1798.83-1798.84 (the Shine
the Light Act) entitles California residents to request disclosure regarding Personal Information sharing with affiliates and/or
third parties for marketing purposes. If you are a California resident and you would like to request a copy of this notice,
please contact us at privacy@cronometer.com with the subject line
“Request for California Privacy Information.”
VARIOUS ADDITIONAL STATE PRIVACY RIGHTS: CALIFORNIA COLORADO,
CONNECTICUT, MONTANA, OREGON, TEXAS, VIRGINIA, and UTAH
Under Colorado, Connecticut, Montana, Oregon,
Texas, Virginia, and Utah law, residents of these states have specific rights regarding their Personal Information. These rights
include:
Right to Access. You have the right to access your Personal Information (known as a “data
subject access request”). This enables you to receive a copy of the Personal Information we hold about you, subject to
exceptions and requirements in the law. If you submit a right to access request, we will provide you with copies of the
requested pieces of Personal Information in a portable and readily usable format. Please note that Cronometer is prohibited by
law from disclosing copies of certain pieces of Personal Information (e.g., government identification numbers, financial account
information, and passwords or security questions and answers) because the disclosure would create a substantial, articulable,
and unreasonable risk to the security of the information, our business systems, or your account.
Right to
Delete. You have the right to request that we delete Personal Information that we collected from you and retained,
subject to certain exceptions.
Right to Data Portability. You have the right to request a copy of
the Personal Information that we collected about you during the 12 months before your request.
Right to
Opt-Out of Sharing or Selling of Your Personal Information. We do not sell your Personal Information. You have a
right to opt-out of the sharing of your personal data. You may, at any time, direct businesses not to share your personal data
with third parties. If you would like to opt-out of sharing, please contact our privacy officer at privacy@cronometer.com. In some
circumstances, opting out of
sharing may mean we or third parties are not able to provide you with certain services.
Non-Discrimination. We will not treat you differently because you exercised a legal right.
Under California, Colorado, Connecticut, Montana, Oregon, Texas, and Virginia laws, residents of these states have these further
rights regarding their Personal Information:
Right to Correct Personal Information. You have the
right to request that we correct inaccuracies in the Personal Information we maintain about you. We depend on you to keep the
information we have about you up-to-date. In circumstances where a correction and deletion of the old information is not
appropriate, we may annotate the information you have asked us to correct.
Right to Restrict Automated
Decision Making. We do not engage in any automated decision making regarding our users. In the event we do so in
the future, we will add a notice to this policy and provide you with a means to exercise your right to restrict us from making
any automated decision that has legal or significant effects for you.
ADDITIONAL PRIVACY NOTICE TO RESIDENTS
OF THE EUROPEAN UNION, UNITED KINGDOM AND CANADA
Cronometer adopted this section to comply with the
European Union’s General Data Protection Regulations (“GDPR”) and other jurisdictions with similar data protection laws such as
Canada. This section applies to Site visitors, users, and others who are residents of the European Union, United Kingdom and
Canada. We endeavor to uphold GDPR principles for data subjects in the EU as well as those in other jurisdictions with similar
rights. Without limiting the foregoing, to the extent that Cronometer’s activities implicate the GDPR or other similar laws now
or in the future, this section provides those individuals with information about our relevant privacy practices.
Data Controller. The data controller of your Personal Information is Cronometer, if you have engaged
us directly. If Cronometer has been engaged to provide services by your school or other primary contact, Cronometer is a data
processor for the primary contact.
Lawful Basis under GDPR. The lawful bases on which Cronometer
processes your Personal Information are: (a) when applicable, with your direct consent; (b) if we have a legitimate interest in
doing so, such as fulfilling our obligations as a data processor to your School, administering our business, maintaining the
quality of our Site and Software, providing customer service, or identifying new business opportunities; and (c) as authorized
or required by law.
Additional rights: you have the following rights in relation to the Personal
Information we hold about you.
YOUR RIGHT
WHAT THIS MEANS FOR YOU
WHAT YOU CAN DO
To know how we process your Personal Information.
We are required to provide notice about the way that we will use the Personal Information we collect.
We have set the required notices in this Privacy Notice. We may provide you with additional notice about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.
To access your Personal Information.
If you request it, we will provide you with access to your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf.
You can request to access your Personal Information (i.e. a copy of it). We may have one or more legally valid reasons to refuse your request in whole or in part, for example in order to protect the rights of other individuals.
To restrict the processing of your Personal Information.
In certain circumstances and to the extent required by law, we are required to restrict our processing of your Personal Information.
You can request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object.
To rectify your Personal Information.
We are required to correct the Personal Information we have about you if you inform us that it is incorrect.
If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (for example you change address) please inform us and we will update our records.
To data portability.
In some circumstances, we are required to provide your Personal Information to another organization at your request and in a format that allows the other organization to read and use it.
You have the right to request that we transfer your Personal Information to another organization (i.e. another data controller) in a structured, commonly used machine-readable format, so that the other organization can read and use it.
To erasure of your Personal Information (a.k.a. the “right to be forgotten”).
Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request.
If you make this request, we balance certain legal, contractual and business interests against your right to request the deletion of your Personal Information.
To object to certain processing of your Personal Information.
Upon your request, and in certain circumstances and where we are required to do so by law, we will limit our processing of your Personal Information as you request.
You may object to the processing of your Personal Information in certain circumstances. If you make this request, we will consider certain legal, contractual and business interests and obligations against your right to object to the processing. You can also object to our use of your Personal Information for direct and/or targeted marketing purposes.
To not be subject to a decision based solely on “automated processing.”
We are required to keep records of automated processing that we carry out, if any, and, in certain circumstances, provide you with information about the way that the decisions are made, and respond to your objections to being subject to decisions made.
We do not currently make decisions about individuals based solely on automated processing. If we engage in this activity in the future, you will have the right to object to a decision we make wholly by a computer or algorithm without human input and to receive information about this type of processing.
If you want to exercise any of these rights,
please make a request to privacy@cronometer.com.
TERMS
Terms
of Use. We encourage you to familiarize yourself with the Site Terms of Use (https://cronometer.com/terms/) which governs
all
matters not set forth in this Privacy Notice.
Changes to this Privacy Notice. We may occasionally make
changes to this Privacy Notice to ensure its accuracy. If we make changes, the revised Privacy Notice will be posted online and
the date of the newest version will be listed. Please check back frequently, especially before you provide us with personal
information, to determine the current scope of the notice.
Governing Law. Those who choose to use or
access the Site and/or Services from outside Canada do so on their own initiative and are responsible for compliance with local
laws, if and to the extent local laws are applicable. Notwithstanding the foregoing, and recognizing the global nature of the
Internet, each viewer and user shall comply with all local rules regarding online conduct and submission of acceptable
materials. This Privacy Policy is governed and interpreted pursuant to the laws of the Province of British Columbia, Canada and
the federal laws of Canada applicable therein, without regard to principles of conflicts of law that would impose the law of
another jurisdiction, and you accept and submit to the exclusive jurisdiction of the courts located within the Province of
British Columbia, Canada.
International Transfer. We may transfer information that we collect about
you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or
jurisdictions around the world. Please note that these countries and jurisdictions may not have the same personal information
protection laws as your own jurisdiction, and you consent to the transfer of information over international borders and the use
and disclosure of information about you, including Personal Information, as described in this Privacy Policy.
CONTACT
INFORMATION
If you have any further questions about our collection and use of your Personal Information,
or if you wish to exercise any of your rights over your Personal Information or if you have any questions about this Privacy
Notice, please contact us at privacy@cronometer.com
Cronometer
Software Inc.
Attention:
Privacy Officer
Address:
Cronometer
Software Inc.,
PO Box 3270
Revelstoke, B.C.
Canada
V0E 2S0
Email:
privacy@cronometer.com
