Last updated October 3, 2023
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 3rd 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”
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.
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 firstname.lastname@example.org.
i. Anonymized Data. We may share information that has been anonymized with others for their own uses.
8. Third-Party Websites
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 email@example.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 firstname.lastname@example.org.
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.
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 email@example.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 firstname.lastname@example.org or via post at:
315 SW 11th Avenue, Third Floor
Portland, OR 97205
16. Commitment to Comply with EU-U.S. Data Privacy Framework (DPF) Principles
To the extent Eleven makes a transfer personal information to a third party acting as a controller is necessary, Eleven will:
To the extent Eleven makes a transfer personal data to a third party acting as an agent, Eleven will: