Different countries, their sub-divisions (like the U.S. state of California) and transnational regions (like the European Economic Area or EEA) define “Personal Information” in many different ways. Adhere views the collection of Personal Information in the broadest terms and considers “Personal Information” as any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or individual.

Adhere attempts under all circumstances to minimize to the greatest extent possible the collection, processing, usage and storing of any Personal Information and only uses Personal Information for the limited purposes described in this Privacy Policy.

Different countries, their sub-divisions (like the U.S. state of California) and transnational regions (like the European Economic Area or EEA) define “Personal Information” in many different ways. Adhere views the collection of Personal Information in the broadest terms and considers “Personal Information” as any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or individual.

Adhere attempts under all circumstances to minimize to the greatest extent possible the collection, processing, usage and storing of any Personal Information and only uses Personal Information for the limited purposes described in this Privacy Policy.

Adhere Service and Registration. Adhere may collect and receive Personal Information in a variety of ways and use them for different purposes. For example, when you sign up for the Adhere Services or attend events and visit our offices, we collect personal data identifiers such as your name, email address, organization name, and other contact information. We also collect other information required to configure, use, and provide support for the Adhere Services including your device IP address, the time you visited, and cookies activity.

Cookies. A cookie is a piece of information that our web server sends to your computer or device (actually to your browser file) when you access a website. Then when you come back to our site, the browser will detect whether you have one of our cookies on your computer or device. Our cookies help provide additional functionality to the website and help us analyze website usage more accurately. We use both our own and third party cookies for statistical purposes and to improve our website. You can set some of your own Cookie preferences or disable them entirely, but doing so may affect the functionality of the Adhere Services, including your receipt of notifications.

IP Address. When you visit our website, we collect your IP address information in order to provide you more relevant content.

The Personal Information we collect is used for various purposes such as:

Providing Services. We may contact you to provision the Adhere Services, provide technical support, track site usage and assist with website account session authentication and to identify you when you visit our website.

Communicating with You About Our Services. The Personal Information collected is used to provide you with information that you request from us. Your email address will be used to notify you of critical updates, account information, and news or announcements that may be of interest to you.

Processing Payments. In limited circumstances, we may use your Personal Data, including your contact data, to administer our business activities and carry out our obligations arising from any contracts between you and us, including invoicing.

Improving our Services. The Personal Information is also used to improve our website and your website experience.

Supporting Security. We use the information to investigate and prevent security issues and abuse. Additionally, such information may be used to respond to law enforcement requests as required by applicable law, court order or governmental regulations.

Marketing Our Products and Services. We may use your Personal Information to send promotional communications that may be of specific interest to you and your organization, including information about new Adhere Services features and to drive customer product engagement.

Sharing of Personal Information. We do not share, sell, rent, or trade any Personal Information that you provide us with third parties, except as required to provide our customers access to the Adhere Services and as otherwise specified in this Privacy Policy.

Storing Personal Information. Adhere uses certain “Third Party Service Providers” to host, maintain and co-locate the applications and functionality that are include in Adhere Services, and such Third Party Service Providers may act as sub-processors of Personal Information we collect, store and process from users of Adhere Services. In addition to the security protections provided by these trusted Third Party Service Providers, Adhere maintains and has implemented its own administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the Personal Information that Adhere receives, maintains, processes or transmits on behalf of such Adhere Service customers and their users.

Attribution. Adhere may include a list of customers of the Adhere Services as well as testimonials on the Adhere website that contain a customer name, logo and associated employee name and title. We include this information on our website only with prior consent of the specific companies, customers and individual users and customer employees.

Public Forums. You acknowledge that any information you post on any Adhere provided blog, bulletin board or similar forum may be freely used by Adhere, any Adhere customer or any other visitor to such forum, and therefore, you shall have no expectation of privacy with respect to any data or information included in such forum.

Required by Law. Adhere reserves the right to use or disclose Personal Information provided by any website visitor or user of Adhere Services if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or legal process.

Adhere retains customer Personal Information for a period of time that is consistent with the purpose of the data collection, or where it has a justifiable business need to do so, such as enforcing our agreements or resolving disputes, or unless a longer retention period is required by law. If neither of the preceding instances apply, Adhere will securely delete, destroy, and remove such Personal Information from our Adhere Services platform and/or instruct Third Party Services Parties to securely delete, destroy, and remove such Personal Information from their own systems.

Adhere Customers. We may share Personal Information we collect through the Adhere Services with our third-party data center service providers that assist us with operating the Adhere Services. Third Party Service Providers that we use are required to protect all data provided hereunder (including any Personal Information) as Adhere confidential information, implement reasonable industry standard security protections and safeguards, secure and maintain key data security qualifications such as ISO 27001 certification and/or SOC-2 reports, and restrict the onward transfer and disclosure of Personal Information to any other third party.

Website Visitors. As you browse Adhereair.com, we place cookies on your computer or device to assist us in marketing our Services to you and so that we can understand your interests in our technology. Our marketing service partners enable us to present our website visitors with information on our Services based on your previous interaction with Adhereair.com. The techniques our partners employ do not automatically collect Personal Information such as your name, email address, postal address, or telephone number. In addition, we use Google, Inc. to collect data to track and examine the use of Adhereair.com by website visitors, to prepare reports on website activities. Google may use the data collected to contextualize and personalize the ads it displays on its own advertising network.

Your Choice: Opt Out. You can choose not to provide certain information to Adhere, but this choice may impair your ability to use the Adhere Services or gain the full functionality of our website. You may also opt out of Google Analytics by visiting the Google Analytics opt-out page.To opt out of Adhere’s general marketing tracking, please send an email to hello@adhere.cc and include “Opt-Out Request” in the subject line.

Do Not Track. Adhere does not respond to ‘Do Not Track’ browser signals or other mechanisms. Third parties may collect Personal Information about your online activities over time and across sites when you visit our website or use the Adhere Service.

Adhere will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual user or visitor. Adhere will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current. We also process the Personal Information of our customers and their users subject to contract terms and conditions. A customer contract is another source of consent that Adhere uses and relies upon as a legal basis of processing Personal Information.

When third party providers and developers use the Adhere Services, data is sent (“Published“) and received (“Subscribed“) through the Adhere Services. Aggregate, non-personally identifiable data Published to, and Subscribed from, the Adhere Services may be used by Adhere to help with the development, tuning and scaling of the Adhere Services, including the generation of reports. Reporting is used both for internal use and to provide reports available to the Adhere customer associated with such provided data. Adhere will keep all data private, and will not share data with any third parties, except as an aggregate data set across multiple Adhere customers (for example, advertising the total number of video sessions conducted on the Adhere Service per day). Occasionally we may use the aggregated data and information collected in this way to notify all our customers about new services or special offers.

Adhere provides various levels of security and the Adhere Service encrypts data on device, in transit, and at rest. Please check the Adhere documentation for up-to-date information on the various security levels offered to third party providers and developers by the Adhere Services. In addition, Adhere takes reasonable measures, including technical, physical, and administrative measures and training, designed to protect Personal Information from loss, misuse, unauthorized disclosure, access, alteration, and destruction. Adhere safeguards Personal Information according to established security standards and periodically assesses new technology for methods of protecting information.

If you are under 18, or under the age of majority in the jurisdiction in which you reside, you may only use the Adhere website and Adhere Services with the consent of your parent or legal guardian.

By accessing and using this Adhere website and/or the Adhere Services, you agree to this Privacy Policy. Your continued use of the Adhere website or Adhere Services constitutes your agreement to this Privacy Policy and any updates. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets to the acquiring company. You acknowledge that such transfers may occur, and that any acquirer or successor of Adhere may continue to use your Personal Information as described in this Privacy Policy without additional consent from you, provided such entity agrees to and adopts the provisions of this Privacy Policy.

If our Privacy Policy or procedures change, we will promptly post those changes to our website. Any such changes will be effective immediately upon being posted, unless otherwise stated in the change. Adhere may share Personal Information with any entity that is affiliated with us for purposes consistent with this Policy.

Our Terms of Service take precedence over any conflicting Privacy Policy provision contained herein with respect to our customers’ use and access rights to the Adhere Services.

You may contact Adhere to request Personal Information held by Adhere in order to correct, amend or delete information that is inaccurate. You may contact Adhere using the information below under the “Contact Us” section.

Adhere complies with the provisions of the Regulation (EU) 2016/679 of the European Parliament, known as the General Data Protection Regulation (“GDPR”). For purposes of Article 14(2) of the GDPR, Adhere relies on the following lawful basis for processing Personal Information (referred to as Personal Data under GDPR): consent, compliance with law and legitimate interests.

Data Processors and Data Controllers. Under GDPR, Adhere acts as a Data Processor with respect to data provided to the company through the Adhere Services by its customers. Adhere acts as a Data Controller with regard to data collected as part of its marketing activities.

Intra-EEA Data Transfers. All transfers of Personal Information internally within the European Economic Area are performed in accordance with GDPR.

Model Clauses. In addition, for those commercial customers on Adhere’s Service plans, Adhere will execute Standard Contractual Clauses (also known as Model Clauses) as defined in Article 29 of GDPR.

Data Security. With respect to any of your Personal Information or Personal Data that is being processed by Adhere and that is subject to GDPR, Adhere shall provide an adequate level of protection of the Personal Information transferred outside the European Economic Area, either by us, our affiliates, and/or third party agents, in accordance with applicable legislation, and in particular by executing the Standard Contractual Clauses approved by the European Commission.

Adhere Privacy Contact. If you wish to exercise any of privacy rights under GDPR, or if you need further information regarding these privacy rights, please contact us at hello@adhere.cc.

Data Controller. In limited circumstances, where Adhere processes your Personal Information as a data controller, you are entitled to the following privacy rights under certain circumstances:

Right of access

Right to rectification

Right to erasure (Right to be forgotten)

Right of restriction of processing

Right to data portability

Right to object

Automated individual decision-making, including profiling

Adhere complies with the California Consumer Privacy Act (“CCPA”) which went into effect as of January 1, 2020. CCPA applies to data collected by certain enterprises involving “consumers” (which means any California resident).

CCPA defines “personal information” as any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

California Notice of Collection; Categories of Personal Information Collected.

Adhere has or may collect information corresponding to the following categories of information enumerated in the CCPA:

Identifiers, including name, email address, account name, IP address – and an ID number assigned to Your account.

Analytics and Advertising, including purchases and engagement with the Services.

Internet activity, including history of visiting and interacting with our Service, browser type, browser language and other information collected automatically.

Inferences, including information about interests and preferences.

For more information on what we collect, please review the section on “Personal Information We Collect and Receive and How We Collect This Information”.

We collect and use these categories of Personal Information for the business purposes described in the section on “How We Use Collected Personal Information”, including to provide and manage the Adhere Services related to our platform.

We do not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in the section “How We Use Collected Personal Information”, we will comply with applicable law as to such activity.

No sale of personal information. In the twelve months prior to the effective date of this Privacy Policy, Adhere has not sold any Personal Information of consumers, as those terms are defined under the California Consumer Privacy Act.

We disclose the following categories of information for commercial purposes:

Commercial Information;

Customer Records;

Location Data;

Inferences; and

Internet activity.

We use and partner with different types of entities to assist us with our daily operations and manage Adhere Services.

Right to Know and Delete. If you are a California resident, you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

The categories of Personal Information we have collected about you;

The categories of sources from which the Personal Information was collected;

The categories of Personal Information about you that we disclosed for a business purpose or sold;

The categories of third parties to whom the Personal Information was disclosed for a business person or sold;

The business or commercial purpose for collecting or selling the Personal Information; and
The specific pieces of Personal Information we have collected about you.

In addition, you have the right to delete the Personal Information we have collected from you. However, this is not an absolute right and we may have legal grounds for keeping such data.

Exercising Your Rights Under CCPA. To exercise any of these rights, please submit a request to hello@adhere.cc. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten (10) days. We may require specific information from you to help us verify your identity and process Your request. If we are unable to verify your identity, we may deny your requests to know or delete.

Authorized Agent. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination. You have the right to non-discriminatory treatment by us, should you exercise any of your rights under CCPA.

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to:

Send information, respond to inquiries, and/or other requests or questions

Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to the following:

Not use false or misleading subjects or email addresses.

Identify the message as an advertisement in some reasonable way.

Include the physical address of our business or site headquarters.

Monitor third-party email marketing services for compliance, if one is used.

Honor opt-out/unsubscribe requests quickly.

Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

Adhere does not collect, process, use or store:

Any medical records or health information as defined under the U.S. Health Insurance Portability and Accountability Act passed by Congress in 1996 (“HIPAA”);

Any banking or other sensitive financial information regulated under Gramm-Leach-Bliley Act (otherwise known as the Financial Modernization Act of 1999) such as non-public personal information (“NPI”), or other sensitive personally identifiable information such as social security numbers, credit card numbers, tax payer identification numbers, or other regulated financial information; or

Special categories of personal data as defined in Article 9 of GDPR.

Adhere commits to promptly responding to your request about our collection or use of your Personal Information. We will respond to such inquiries within the time periods described in relevant laws, including GDPR and CCPA. Any inquiries or requests regarding our Privacy Policy or your Personal Information should be directed to Adhere at:

Email: hello@adhere.cc

Postal mail: 434 HARROP ST, OGDEN CITY, UT, 84404

If there are any general questions regarding this Privacy Policy, you may contact us using this information:

Email: hello@adhere.ccattention to Adhere’s Chief Privacy Officer.

Postal mail: 434 HARROP ST, OGDEN CITY, UT, 84404

Last Update: February 22, 2020

Prior Privacy Policy Dated May 24 ,2018