Eleven Software (“Eleven,” “we,” “us,” or “our”) provides a guest Wi-Fi software service (the “Software”) that enables hotel, cruise and other consumer brands to offer Wi-Fi to their customers and guests.

This privacy policy (“Policy”) sets forth the personal data that Eleven collects from you through our interactions with you, the interactions of third parties who support us or who work with us to provide Services to you, and through our products and services. The Policy discusses how we use that personal data and how you may interact with us about your personal data. If we collect or use such data at the instruction of and on behalf of our brand customers to deliver the Service, we will process and store such data according to those brands’ privacy policies between them and you. This Policy covers:

• What’s New
• Scope Of The Policy
• Mobile Terms and Conditions
• Information We Collect
• How We Use The Information We Collect
• “Do Not Track” Requests
• How We Share Your Information With Third Parties
• Preferences And Opting Out
• Accessing/Correcting/Updating/Removing/Retaining Your Information
• Security
• California Privacy
• General Data Protection Legislation
• EU-U.S. Data Privacy Framework (DPF)
• Third Party Websites
• Social Media Features
• Blogs
• Frame
• Use By Children
• Privacy Policy Changes
• How You Can Contact Us

Please read this 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, your choice is to not use our Services. By accessing or using the Services, you agree to this Policy. This Policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

1. What’s New

We’ve updated our policy regarding how we handle data transferred from the European Union, United Kingdom, and/or Switzerland.

2. Scope of the Policy

This Policy applies to data provided through the Software, as well as any data provided by you to Eleven via support ticketing systems, knowledgebase and forums, web contact forms for sales/marketing or other inquiries (our “Sites”), as well as via email, phone and other methods of communication (“Communications”) and any support services we may offer (“Support”).   Collectively the Software, Sites, Communications and Support, are the “Services” that are subject to this Policy.

This Policy does not apply to any third party site or service linked to our Sites or recommended or referred to by our Sites or by our staff. Applications may be posted by Eleven and/or third parties. When applications are posted by Eleven and the application links to this Privacy Policy, this Privacy Policy applies. When applications are posted by third parties, the privacy policy of the third party applies. 

3. Mobile Terms and Conditions

By providing your mobile phone at opt-in, you consent to receive future automated text messages to the mobile number provided to Eleven. You also acknowledge that your agreement to receive these messages isn’t required as a condition of using our Services.

 Message and data rates may apply and you should check with the rates of your mobile carrier. All charges are billed by and payable to your mobile service provider. Eleven does not charge you for sending or receiving text messages in connection with the services we provide.   You can unsubscribe at any time by texting "STOP" to the short code. A text will be sent back confirming your removal. After this text you will no longer receive SMS messages from us.

This service may not be available on all mobile carriers. Eleven is not liable for any delays in the receipt of any SMS messages or undelivered messages.

 Data obtained from you in connection with this SMS service includes your cell phone number, your carrier's name, the date, time and content of your messages, and other information you provide to Eleven as part of this service. We use this information only to contact you regarding the Services we are providing to you. Your mobile information will not be shared with any third parties.

4. Information We Collect

We collect information from you in several ways. First, you provide us with certain information when you register for, download, access, and otherwise use our Services. Second, we collect certain information automatically as you interact with our Services. Third, we may get information about you from other sources. We may collect personal information from you when you register as a user or to learn more about our products, request a demo or evaluation software, provide comments and suggestions, sign up for newsletters, enter promotions, interact with us on our social media channels, order products or services, request and utilize maintenance and support services, request white papers, sign up for events or seminars, submit content or send us feedback. If you do not want us to collect this information, please do not provide it. We directly collect the following types of information that you provide to us:

a. Information You Provide to Us

         i. User information. This means information collected about users of the Services and includes without limitation contact information such as name, email address, address, and phone number, room number or other information that you may provide to us or to customers using our Services in an online form, or when you contact us by email or telephone, and any other information you may provide us when you sign up for the Services, including payment information and coupon codes.

         ii. Business account information. This means business-contact information such as name, title, job function, business name, business address, business email address, and business phone number that we collect about people we serve or work with, including actual and prospective customers, alliance and channel partners, contractors, vendors and other parties interested in Eleven or its products and services. Customers of Eleven may access customer support portions of our Sites via a personal login and password. When you access our Sites as a customer, you will have the opportunity to review, correct, and update certain of your account information. We use this information to support your account, respond to your inquiries, perform accounting functions, provide you with information about us, our products, and services, and to otherwise maintain our business relationship with you.

        iii. Customer proprietary information. This means information that is owned by our customers and provided to us or collected by us on behalf of our customers to provide our Services and includes without limitation information about individuals necessary for them to access and use the Services from our customers’ branded sites. Eleven respects the privacy of all customer proprietary information and views it as the customer’s property. We do not control what customer information we may receive and host, or what steps you have taken to ensure that the data is reliable for its intended use, non-infringing, accurate, complete, and current. Eleven has no direct relationship with the individuals whose personal data is customer proprietary information, and Eleven may not have access to such personal data. Eleven will use customer proprietary information to fulfill our obligations under our Eleven End User License and Services Agreement or similar agreement with the customer and to identify other Eleven products which may benefit the customer. For instance, we may be engaged by the customer to help upload its data, to assist with configuration, or to provide support services. If you provide any personal information about any third parties, including your clients, to Eleven, you are responsible for providing any notices and obtaining any consents required by applicable law necessary for Eleven to access, and use, process, and disclose that personal information.

b. Information We Automatically Collect from You When You Use the Services. The information we collect automatically is statistical information and may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. If you do not want us to collect this information, please do not use the Services.

     i. Information collected through our cookies, web beacons and other tracking technologies. We (or service providers on our behalf) may use technologies, including “cookies” and “web beacons,” to automatically collect information from you when you use the Services. We collect this information to, among other things, improve our Services and your experience, see which areas and features of our Services are popular and count visits, provide you target advertising based upon your interests and are used in analyzing trends, administering the site, tracking users’ movements around the site, to gather demographic information about our user base as a whole, and to remember users’ settings and for authentication purposes. Cookies are small amounts of data that are stored within your Internet browser, which saves and recognizes your browsing habits. Eleven uses both session cookies (which track a user’s progression during one site visit) and persistent cookies (which track a user over time). Web beacons (also called pixel tags or clear GIFs) are web page elements that can help deliver cookies, count visits, track browser type, identify your IP address, understand usage and marketing campaign effectiveness, recognize certain types of information on your computer, in your email or on your mobile device, such as the time and date you viewed a page, which emails are opened, which links are clicked, and similar information.

     ii. Log files. As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses and usage data such as browser type, browser language, device identifier, Internet service provider (ISP), referring/exit pages, length of visit, pages viewed, operating system, date/time stamp, clickstream data, crashes, system activity, hardware settings, the date and time of requests, referral URL and other usage data. We may combine this automatically-collected log information with other information we collect about you. If you reach out to us over the telephone or via facsimile, we may also log telephony information such as your phone number, forwarding calls, SMS routing information and types of calls.

     iii. Services Use. We may use technologies to automatically collect information from you when you use the Services, including without limitation details of how you used our Services and your search queries. We collect this information to, among other things, provide you information and benchmarking based upon your usage of the Services, which are used in analyzing trends, administering the Services, tracking users’ utilization and to gather information about our customer user base as a whole.

     iv. Device Information. We collect information about the device you use to access our Site and our Services, including without limitation the hardware model, operating system and version, unique device identifiers and mobile network information. We may associate your device identifiers and phone number with the account(s) you opened with us.

     v. Location Information. When you use our Services, we may collect and process information about your actual location. We may use IP address, beacons, GPS and other sensors that provide information about nearby devices, Wi-Fi access points and cell towers.

     vi. Application Information. Some of our Services use a unique application number, and we may receive the unique application number and information about your installation including without limitation application version number and operating system when you install or uninstall the service or when the service contacts our servers such as for automatic updates.

     vii. Local Storage of Information. Our Services may collect and store information locally on your device, including without limitation browser web storage and application data caches.

c. Information We Get From Others. We may get information about you from other sources. We may add this information to the information we collect on you from this Site. This information may include data collected or validated from brands or other third parties.

 

5. How We Use the Information We Collect

We may use information collected from or about you for any of the following purposes:

a. Authentication. Authenticate your identity to grant guest Wi-Fi access at a venue operating by an Eleven partner or customer. Authentication may include gathering information, validating against 3^rd party systems like social media or enterprise authentication systems, or other means of identifying you.

b. To provide Services at the instruction of our customers. We may use personal information we or our customers have collected from you to provide our Services at our customers’ branded websites.

c. To respond to your requests or to tailor content. We may respond to your requests, which may include processing orders, sending confirmations, providing invoices, processing requests for information about our products and processing downloads for white papers or product demonstrations or evaluations. We may also use your information to customize your interaction with our Site and to provide you with more relevant information and advertisements.

d. To provide services to you. We may communicate with you about our Services. These may include reports, consulting, educational, training, maintenance and support services for which you have inquired or contracted. For instance, as part of support services, our technical staff may require periodic access to services data to troubleshoot or monitor your system. We may provide technical support and related product information via customer support portal. We may require access to your systems to implement our Software. Any temporary copies of data accessed, used or created as a necessary part of this service are only maintained for time periods relevant to those purposes. As part of these services, we may be required to remotely access your systems or an individual computer in order to troubleshoot a support issue or have direct physical access as part of an onsite engagement. We may also use this data to provide you service and product updates and notices. We may keep a record of your communications and ours to provide improved customer service to you and others, including without limitation recordings of customer support phone calls.

e. To provide informational services. We may use personal information while providing online forums such as user groups and bulletin boards. We may also do so while delivering live or online events such as training seminars or conferences, including third-party events sponsored by Eleven.

f. Prevent improper or illegal activity. We may use information to protect, investigate and deter against fraudulent, unauthorized or illegal activity.

g. To meet legal requirements. Eleven may be required to provide personal information to comply with legally mandated reporting, subpoenas, court orders, or other legal process requirements.

h. To market and improve our products and services and to create new products and services. We may inform you about our products, services or events and otherwise perform marketing activities. Further, we may use information for analytics purposes and to operate, maintain and improve our products and services. We may also use information to create new products and services.

i. Verify users. We may use personal information to manage and verify your account and the identity of users of the Services.

j. Contests and rewards. We may use information to process contest entries and deliver rewards.

k. Other purposes. We may use personal information for any other legal, business or marketing purposes that are not inconsistent with the terms of this Policy.

 

6. “Do Not Track Requests”

Your Internet browser and mobile device may allow you to adjust your browser settings so that “do not track” requests are sent to the websites you visit. We do not process “do not track” (DNT) signals. Our third party service providers may also not respond to DNT signals.

7. How We Share Your Information with Third Parties. Eleven may disclose personal information in the following circumstances:

     a. Customers. When Eleven delivers the Service at the instruction of its customers, the personal information collected is shared with and owned by its customers subject to the applicable Customer’s privacy policy.

     b. Business Partners and Subcontractors. Eleven shares personal information with business partners and subcontractors (such as third-party distributors and resellers, vendors, suppliers and other service providers), who may use the information to fulfill product orders, develop and improve products, contact you about product orders or in connection with the performance, operation, and support of the Services or solutions, performing marketing or consulting services, or as otherwise appropriate in connection with a legitimate business need. Further, we may disclose personal information to service providers who host or facilitate the processing of payments, the ability of individuals to access the services, delivery of online training, seminars and webinars; email-delivery services and other technology providers; and third parties that may assist in the delivery of marketing materials, technical support services, or other products, services or other information. These companies are authorized to use your personal information only as necessary to provide these services. Onward transfers of customer proprietary information to third parties remain subject to the agreements with our Customers.

     c. Third Party Analytics Providers. Eleven shares personal information with third parties who conduct marketing studies and data analytics, including those that provide tools or code which facilitates our review and management of our Services, such as Google Analytics or similar software products from other providers. For example, we use Google Analytics to analyze site traffic to our Sites and apps. We may also use Google Analytics in conjunction with Google’s advertising services, such as those using the DoubleClick cookie. With this capability, we or Google may link Google Analytics information with information about visits to multiple sites. We use these tracking technologies to provide tailored advertising and evaluate our marketing efforts. For more information about how Google collects and processes data when you visit websites that use Google technologies, please see “How Google uses data when you use our partners' sites or apps” at google.com/policies/privacy/partners.

     d. Partners. Eleven shares personal information with authorized reseller partners so that they may follow up with you regarding Eleven products and services.

     e. Transfer or Assignment in Connection with Business Transfers or Bankruptcy. In the event of a merger, acquisition, reorganization, bankruptcy or other sale of all or a portion of our assets, personal information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your personal information and other information we have collected from users of the Services or individuals who provide us personal information under this privacy policy to third parties. Other than to the extent ordered by a bankruptcy or other court, or as otherwise agreed to by you, the use and disclosure of all transferred user information will be subject to this Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

     f. Response to Subpoenas or Court Orders; Protection of Our Rights; Safety. Eleven shares personal information as required or permitted by law, regulation, legal process or other legal requirement, or when we believe in our sole discretion that disclosure is necessary or appropriate, to respond to an emergency or to protect our rights, protect your safety or the safety of others, investigate fraud, comply with a judicial proceeding or subpoenas, court order, law-enforcement or government request, including without limitation to meet national security or law enforcement requirements, or other legal process and to enforce our agreements, policies and terms of use.

     g. Publicly Posted Content. If you post comments, images, and other content to a public-facing page, that information (associated with your username) will be publicly viewable.

     h. With Your Consent. We may share some or all of your information to any other third party with your affirmative consent. For instance, we display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@elevensoftware.com.

     i. Anonymized Data. We may share information that has been anonymized with others for their own uses.

 

8. Third-Party Websites

Our Sites contain links to third party websites. We are not responsible for the data collection, use practices, policies, or cookie use of the third party sites that you have accessed from our Sites. We encourage our users to be aware when they leave our Site(s) and to read the privacy policies of each website that collects personal information. This Policy applies solely to information collected on or through our Services.

9. Social Media Features

Our Services may include social media features, such as the Facebook Like button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing it.

10. Blogs

Our Services may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy@Elevensoftware.com. In some cases, unless required by applicable law, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

11. Frame

Some of our pages utilize framing techniques to serve content from our partners while preserving the look and feel of our Services. Please be aware that you are providing your personal information to these third parties and not to us.

12. Preferences and Opting-Out

a. Our Services provide visitors and customers the opportunity to opt-out of receiving specific types of communications from us and our partners at the point where we request information about the visitor or customer. In addition, if you have previously signed up to receive information about our Services, you may unsubscribe or opt out of all future marketing communications from us that do not relate to products or services you have already ordered by removing your contact and personally identifiable information from our marketing and communications databases by (a) sending an email to privacy@elevensoftware.com; or (b) clicking the unsubscribe link on any email marketing communication you receive.

b. If you choose to use our referral service to tell a colleague about our Eleven community site, we will ask you for your colleague’s email address. We will automatically send your colleague a one-time email inviting him or her to visit the site. Eleven does not store this information. Further, if you register for an account, you may automatically be listed in our publicly accessible member directory. If you do not wish to be listed in the directory, please do not register for an account or contact us to have your account closed. If you wish to request removal of your information from this public directory, you can contact us at privacy@elevensoftware.com.

We may partner with a third party to manage our advertising on other sites. Our third party partner may use cookies or similar technologies to provide you advertising based upon your browsing activities and interests. Most Internet browsers allow you to block or delete cookies from your browser. If you do not agree to the use of these cookies, please disable or delete them by following the instructions for your browser set out here: http://www.allaboutcookies.org/, or use automated disabling tools where available. You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) (Link) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (Link) by visiting the opt-out pages on the NAI website and DAA website. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. You can also delete cookie files from your hard drive, or avoid them altogether, by configuring your browser to reject them or to notify you when a cookie is being placed on your hard drive. Not all features of the Services will function as intended if you reject cookies.

13. Accessing/Correcting/Updating/Removing/Retaining Your Information

You have the right to access your personal information and to correct, amend, or delete such personal information if it is inaccurate (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to your privacy or the rights of other persons). You can access, correct, or request deletion of your personal information by logging into your account. Requests for access, correction, amendment, or deletion should be sent to privacy@elevensoftware.com. If your personal data is customer proprietary information, you should direct your requests to Eleven’s customer, and Eleven’s customer shall respond.

Upon request, Eleven will provide you with information about whether we hold any of your personal information. We will respond to any request to access your personally identifiable information within 30 days. It may take us longer if your request is complex or you have made multiple requests in which circumstances we will notify you and keep you apprised of our progress. We will retain your information and the data we process on behalf of our customers for as long as your account is active or as needed to provide you services. We will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you delete any account information, we may retain certain information as required by law or for legitimate business purposes.  

If you become an inactive customer, or if we close or suspend your account, we will continue to adhere to the then-current Policy when we collected your personally identifiable information so long as we retain it in our databases. We may delete any or all of your information at any time without notice to you for any reason or no reason unless otherwise required by law to retain it.  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your information (or to exercise any of your other rights). This is a security measure to ensure that your information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

14. California Privacy

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Eleven to a third party for the third party’s direct marketing purposes. To make such a request, you can fill out this form, call us at 1-866-435-3836, send an email to privacy@elevensoftware.com, or write us at:

Eleven Software
Attn: Privacy
315 SW 11^th Avenue, Third Floor
Portland, OR 97205

 

15. General Data Protection Legislation – Applicable to users in the European Union (EU), United Kingdom (UK), and Switzerland

Eleven is committed to cooperating with the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and to comply with the advice given by such authorities with regard to non-human resources data transferred from the EU, UK, and/or Switzerland. If you are a resident of the EU, UK, or Switzerland, the following information applies.

Right to lodge a complaint: Users who reside in the EU, UK, or Switzerland have the right to lodge a complaint about our data collection and processing actions with the appropriate supervisory authority. Contact details for data protection authorities are available here.

Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we maintain facilities. In compliance with the General Data Protection Regulation (GDPR), we will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR.

Individual Rights: If you are a resident of the EU, UK, or Switzerland, you are entitled to the following rights under the GDPR. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you.

• The right to request data erasure. You have the right to have your data erased from our Services if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
• The right to restrict or object to our processing. You have the right to restrict or object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.
• It is possible, under certain circumstances, that you may invoke binding arbitration of claims.  

Please note that Eleven is required to disclose personal information about you in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Please direct any inquiries regarding your personal information transferred to the United States to privacy@elevensoftware.com.

Eleven commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States. EU, UK, and Swiss individuals with inquiries or complaints regarding transfer of their data should first contact Eleven by email at privacy@elevensoftware.com or via post at:

Eleven Software
Attn: Privacy
315 SW 11th Avenue, Third Floor
Portland, OR 97205

16. Commitment to Comply with EU-U.S. Data Privacy Framework (DPF) Principles

• Eleven is committed to complying with the DPF Principles.
  • These Principles are your rights to (click to view each Principle):

Notice
Choice
Accountability for Onward Transfer
Security
Data Integrity and Purpose Limitation
Access
Recourse, Enforcement and Liability

• Questions about the DPF Principles or complaints about our compliance with such Principles can be directed to the U.S. Department of Commerce’s DPF program website (Home (dataprivacyframework.gov).
• You are also able to submit a complaint directly to your local data protection authority: You can always submit a complaint directly to your local data protection authority  (i.e., EU/EEA Member State data protection authority; UK Information Commissioner’s Office (ICO) or Gibraltar Regulatory Authority (GRA); or the Swiss Federal Data Protection and Information Commissioner.  Your data protection authority may refer your complaint directly to the U.S. Department of Commerce’s International Trade Administration (ITA) on your behalf.  If referred to the ITA, the DPF team will then work with Eleven to seek to resolve your concern, within 90 days.

A. Providing free and accessible dispute resolution

• Individuals may bring a complaint directly to Eleven, and we will respond to you within 45 days.
• Eleven will, at no cost to you, provide an independent recourse mechanism by which your complaint can be investigated and expeditiously resolved.
• Participating organizations must also commit to binding arbitration at the request of the individual to address any complaint that has not been resolved by other recourse and enforcement mechanisms.

B. Cooperation with the U.S. Department of Commerce

• Eleven will respond promptly to inquiries and requests by the ITA for information relating to the EU-U.S Data Privacy Framework (EU-U.S. DPF) and, as applicable the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

C. Maintaining data integrity and purpose limitation

• If Eleven receives your personal information it will be to the limited extent necessary for processing as you have permitted.
• Eleven will comply with the data retention provision of the DPF.

D. Ensuring accountability for data transferred to third parties

To the extent Eleven makes a transfer personal information to a third party acting as a controller is necessary, Eleven will:

• Comply with the Notice and Choice Principles of the DPF; and
• Enter into a contract with the third-party controller that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by you and that the recipient will provide the same level of protection as the DPF Principles and will notify Eleven if it makes a determination that it can no longer meet this obligation. The contract shall provide that when such a determination is made the third-party controller ceases processing or takes other reasonable and appropriate steps to remediate.

 To the extent Eleven makes a transfer personal data to a third party acting as an agent, Eleven will:

• Transfer such data only for limited and specified purposes;
• Ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the DPF Principles;
• Take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with Eleven’s obligations under the DPF Principles;
• Require the agent to notify Eleven if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles;
• Upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing; and
• Provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the U.S. Department of Commerce upon request.

E. Transparency related to enforcement actions

• Eleven will make public any relevant DPF-related sections of any compliance or assessment report submitted to the Federal Trade Commission (FTC) or the U.S. Department of Transportation if Eleven becomes subject to an FTC or court order based on non-compliance.

F. Ensuring commitments are kept as long as data is held

• If Eleven leaves the relevant part(s) of the DPF program, it must annually affirm to the ITA its commitment to apply the DPF Principles to information received under the relevant part(s) of the DPF program if it chooses to keep such data; otherwise, it must provide “adequate” protection for the information by another authorized means.

17. Use by Children

The Services are not intended for users younger than 16. We do not knowingly collect contact information from children under the age of 16 without verifiable parental consent. If we become aware that a visitor under the age of 16 has submitted personal information without verifiable parental consent, we will remove his or her information from our files.   When Eleven delivers the Service at the instruction of its customers, it is possible that we may process information about you if you are under the age of 16 under the instruction of our customers and such processing shall be subject to our customers’ process for obtaining appropriate consents for such processing and shall be subject to our customers’ privacy policies.

18. Security

Eleven takes reasonable and appropriate measures to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the personal information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about our security, you can contact us at privacy@elevensoftware.com. We have put in place procedures to deal with any suspected breach of personal information, and we will notify you and any applicable regulator of a breach where we are legally required to do so.

19. Privacy Policy Changes

We reserve the right to modify this Policy at any time. When we make only minor modifications, we may do so without notifying you. It is your responsibility to keep the contact information we have on file for your designated representative current. When we make material modifications affecting data practices where we operate as the data controller, we will post and/or email the new Policy. We will notify you either by means of a notice on this website prior to the change becoming effective or at our election we may email you by sending an email to the email address specified in your account. We encourage you to periodically review this page for the latest information on our privacy practices. The Last Modified Date at the top of this Policy will allow you to quickly know when the last changes were made, and the “What’s New?” section will highlight the changes from the most recent version of the Policy.

20. How You Can Contact Us

If you have questions or concerns regarding this Policy, you should contact us by email at privacy@elevensoftware.com. You can also write to us at:

Eleven Software
Attn: Privacy
315 SW 11^th Avenue, Third Floor
Portland, OR 97205