Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4 Our website incorporates privacy controls that affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via the subscription link.

1.5 In this policy, “we”, “us” and “our” refer to Heretto and its employees.  Heretto is a Service Mark of Jorsek, Inc., a Delaware corporation, DBA Heretto.  For more information about us, see Section 16.

2. How we use your personal data

2.1 In Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is HubSpot and Google Analytics. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you.

We process personal information for certain legitimate business purposes, which include some or all of the following:

• where the processing enables us to enhance, modify, personalize or otherwise improve our services/communications for the benefit of our customers to provide services requested by you or by your company
• to enhance the security of our network and information systems
• to better understand how people interact with our websites
• to provide communications which we think will be of interest to you
• to determine the effectiveness of promotional campaigns and advertising.

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Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing if you wish, and if you wish to do so please click here. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.

3.4 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include name, email address, title, and employment details. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you.

3.5 We may process information contained in any inquiry you submit to us regarding goods and/or services (“inquiry data“). The inquiry data may be processed for the purposes of offering, marketing, and selling relevant goods and/or services to you.

3.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

3.8 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms and online chat. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.9 We may process and share any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

3.10 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.12 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4. Providing your personal data to others

4.1 We may disclose data to any member of our group of companies (this means our subsidiaries, our ultimate holding company, and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy.

4.2 Financial transactions relating to Heretto are handled by our payment services provider, Zoho. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.zoho.com/privacy.html.

4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, to prevent illegal activity, to protect our information assets, or in order to protect your vital interests or the vital interests of another natural person.

5. Security

5.1 We employ reasonable and current security methods, including physical, technical, and administrative safeguards, to prevent the loss, misuse, unauthorized access, disclosure, alteration, and destruction of information.  We update and test our security technology on an ongoing basis. When you voluntarily disclose personal information online, for example, in public areas or through email, others can collect and use such information.  No data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your personal information, we cannot ensure or guarantee the security of any information transmitted to us, and you transmit such information at your own risk.

6. International transfers of your personal data

6.1 We have offices in the United States of America (USA). Information we collect from you will be processed in the United States.  The United States has not sought nor received a finding of “adequacy” from the European Union. We collect and transfer to the United States only with your consent, to perform a contract with you, or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.  We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this privacy policy.

6.2 The hosting facilities for our website are situated in the USA.

6.3 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

7. Retaining and deleting personal data

7.1 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.2 We will retain your personal data as follows:

(a) Profile data containing personal data will be retained for two years following your last login, if you have not logged in for over two years, you will be notified of this. If we have not received notification within 30 days of your intent to use your account we will delete your profile data and notify you of this deletion.

(b) Cookie data will be retained for no longer than 90 days.

7.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of personal data will be determined based on the current practice in the industry.

7.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8. Amendments

8.1 We may update this policy from time to time by publishing a new version on our website.

8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

8.3 We may notify you of changes to this policy by email or through the private messaging system on our website.

9. Your rights

9.1 The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects.  Because we are not established in the European Union, these rights only apply in relation to our offering of goods or services to data subjects in the European Union, or in relation to our monitoring of behavior in the European Union.  Among these rights is the right to know the purpose of the processing; the categories of personal data concerned; who else outside of our organization might have received the data from us; what the source of the information was (if you did not provide it directly to us); and how long the data will be stored. Additionally, you have the right to access and rectify your personal data if it is inaccurate.  You may, under certain circumstances, also request that we cease using your data for direct marketing purposes, or that we erase your data. You may also have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal data. We will, at your request, provide personal data that you have provided to us to you or transmit it directly to another controller if technically feasible.

9.2 We do not specifically collect information about children.  If we learn that we have collected information from a child under the age of 13, we will delete the information as quickly as possible.

10. About cookies

10.1 Like many websites, we use commonly-used information-gathering tools, such as cookies, to collect information as you navigate our website.  We also automatically collect certain information, such as internet protocol (IP address), browser type, operating system, and other usage information, and stores that information in log files.  We use this information to analyze trends, administer our website, track your navigation around our website, serve targeted advertising and gather broad demographic information.

10.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

10.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

10.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

11. Cookies that we use

11.1 For information about the cookies that one of our clients uses please email us at: marketing@heretto.com.

12. Cookies used by our service providers

12.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

12.2 We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

12.3 We use Hubspot to analyze the use of our website. This service uses cookies for tracking and identifying visitors to create reports about the use of our website. You can view the privacy policy of this service provider at https://legal.hubspot.com/privacy-policy.

13. Managing cookies

13.1 You have many choices with regards to the management of cookies on your computer.  All major browsers allow you to block or delete cookies from your system, but if you choose to block or delete cookies, it may limit your use of certain features or functions on our website.  To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser.

14. Do Not Track

14.1 We do not respond to web browser “do not track” signals or other similar mechanisms.

15. Third-Party Practices

15.1 Our website may contain links to other websites that have their own separate terms and conditions and privacy policies.  We have no control over and assume no responsibility for, the content, policies, and practices of any third-party websites.  The terms and conditions and privacy policies of such websites govern your use of the services offered on those websites.

16. Our details

16.1 This website is owned and operated by Heretto.  Heretto is a Service Mark of Jorsek Inc., DBA Heretto.

16.2 Our principal place of business is at 130 N Winton Road Box 10250, Rochester, NY, 14610 USA

16.3 You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form;

(c) by telephone, on +1 877-492-2960; or

(d) by email, using info@heretto.com

17. Credit

17.1  This document was created using a template from SEQ Legal (https://seqlegal.com).