What is Personal Information?
“Personal Information” means any information relating to an identified or identifiable natural person, such as first and last name, address, email address, company and department, and/or other types of contact information. An identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
What Personal Data Do We Collect and How Do We Collect It?
When accessing or interacting with our Website, you may be asked to provide us with certain Personal Information. For example, in order to access certain portions of our Website, request information about our products or services or request user support, you may be asked to provide your contact information (e.g., name, institution/company and department, phone number, email address, zip or postal code, etc.). You may be asked to provide Personal Information in order to create an account on our Website or to submit a user support request. Emulate does not collect, store or transmit credit card or payment information.
Not all of the information that we collect about you will always come directly from you. For example, it may come from the institution/company with which you are employed if it is a customer/user of our products and/or services.
To improve your experience on our Website and/or to facilitate our efforts to market our products and services, we may use automatic data collection technologies and/or web-based automated marketing solutions to collect certain non-Personal Information about your equipment, browsing actions/patterns and online activities (i.e., behavioral tracking), including:
- Details of your visits to our Website, including traffic data, location data, logs (e.g., length of visit and number of page views), and other communication data and the resources that you access and use on the Website; and
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The technologies we use for this automatic data collection may include:
- Web Beacons. Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Emulate, for example, to count users who have visited those pages and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
We do not collect any Personal Information automatically, but we may tie the non-Personal Information described above to Personal Information about you that we have collected from other sources or that you provide to us.
If you receive promotional or informational emails from us, you may opt out of these communications at any time by using the “unsubscribe” link at the bottom of all emails.
How Do We Use Personal Information?
We may use Personal Information we collect for the following business purposes:
- To improve and market our products and services;
- To respond to general inquiries or provide technical and user support and training;
- To communicate with you regarding any account you establish on our Website (including specific functions such as successful account creation or password resets) or otherwise provide you with news, marketing and event communications about our products and services (which you can opt out of by following the unsubscribe instructions included in electronic communications or by sending an email to firstname.lastname@example.org);
- To personalize your experience and to make recommendations regarding our products and services;
- To verify your identity;
- To comply with legal obligations, including the prevention, detection and/or investigation of fraud, abuse, security incidents and any harmful activity; and
- To ensure the adequate performance of any contract we may have with you.
Do We Share Personal Data?
We may disclose your Personal Information to third parties under the following circumstances:
- We may disclose your Personal Information to our contractors, service providers and other partners (including without limitation, hosting and platform providers), who support our Website and/or our business and/or who process payments on our behalf. We may also share your Personal Information with service providers who provide data analysis services, customer relationship management solutions and B2B marketing automation solutions so that we can effectively manage our relationship with you as a customer and inform you about our products and services that may be of interest to you.
- We may disclose your Personal Information when we believe in good faith that such sharing is reasonably necessary to investigate, prevent or take action regarding possible illegal activities or to comply with legal process.
- We may disclose your Personal Information to third parties: (i) in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets and (ii) in connection with a merger or other acquisition or if substantially all of our assets are acquired by a third party, in which case Personal Information will be one of the transferred assets.
Where Do We Store and Process Personal Data?
Emulate may transfer, store and process your Personal Information with service providers based in the United States. If you visit our Website from outside the United States, your Personal Information will be transferred to the United States. You acknowledge that United States laws may differ from, and not offer the same level of data protection as, the laws applicable to your country of residence.
How Do We Secure Personal Data?
How Long Do We Retain Personal Data?
We generally retain Personal Information for as long as needed for the specific business purpose(s) for which it was collected. In some cases, we may be required to retain Personal Information for a longer period of time based on laws or regulations that apply to our business or for other necessary business purposes.
What Rights Do You Have to Access and Control Your Personal Data?
You have the right to request access to your Personal Information we have on file by contacting us at email@example.com. In order to comply with your request, we may ask you to verify your identity. We will fulfill your request by sending you a copy of your Personal Information electronically.
In addition, we will honor any request you make to update, correct or delete your Personal Information or suspend processing of your Personal Information, subject to and in accordance with our rights and obligations under applicable law. Please contact firstname.lastname@example.org with any such requests.
We respect your right to access and control your Personal Information and, as such, will make reasonable efforts to respond promptly to any lawful requests described in this section in accordance with applicable laws. If you are not satisfied with the way that Emulate manages your Personal Information, you have the right to make a complaint to the applicable data protection authorities.
Links to Third Party Websites
We do not knowingly collect or solicit Personal Information from children under the age of 13. If we learn that we have collected Personal Information from a child under the age of 13, we will delete that information as quickly as possible.
Do Not Track
Our Website does not support Do Not Track at this time. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit www.donottrack.us.
Special Notice to California Residents
Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. Emulate does not share any information about you to third parties for marketing purposes, however, to make such a request, please contact us using the contact information provided in the “How to Contact Us” section below and provide us with your name, address and email address. We will respond to you within thirty (30) days of receiving such a request.
How to Contact Us
If you have any questions, comments or notices regarding these Terms, you may contact us in one of the following ways:
Attn: Legal Department
27 Drydock Avenue, 5th Floor
Boston, MA 02210 USA
Additional Information for EU Residents
The Personal Information you provide to us includes “personal data” as defined by and subject to any national law of an EU member state adopted pursuant to General Data Protection Regulation (EU) 2016/679. Emulate is the “controller” of the personal data you provide to us. As discussed above, we will transfer your personal data to the United States where our offices are located. We will only transfer your personal data to the United States through the use of appropriate safeguards.
We process personal data as necessary to pursue our legitimate interest to provide our services to you. You have the right to access a copy of your personal data, correct inaccuracies in your personal data, request the erasure of your personal data and restrict the processing of your personal data. For more information about how you can access, rectify and erase your personal data, please contact us at the contact information provided in the “How to Contact Us” section above. In addition, you have the right to lodge a complaint with a supervisory data protection authority.
Version 1: Effective June 12, 2018
Version 2: Effective December 17, 2018
Version 3: Effective April 4, 2019
Version 4: Effective May 9, 2019
Version 5: Effective September 16, 2019
Version 6: Effective October 1, 2020
Version 7: Effective June 22, 2021