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Privacy Policy

Effective from June 1, 2021 

Your privacy is of paramount importance to Emtrey. Emtrey and its affiliates are referred to collectively in this policy as “Emtrey”, “we”, “us” or “our.” Our affiliates are:

  • Emtrey Inc.
  • Horizon Two Labs, LLC
  • H2W Consulting, LLC
  • Heir To Wisdom, LLC
  • Sombra Group

Our Privacy Policy explains how we collect, use, disclose, and protect information that applies to our Service, and your choices about the collection and use of your information. This Privacy Policy covers all websites, web apps, and browser extensions operated by Emtrey including emtrey.com (the “Service”), but it does not apply to any products that display or reference a different privacy policy. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Service.

1. How We Collect Information

The information we collect depends on how you interact with us, the Services you use, and the choices you make. We collect and process information about you with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests. We collect information about you in various ways when you use our products, including information you provide directly, information collected automatically, and third-party data sources:

Information you provide us directly: We collect information you provide to us, such as your organization or company name, first and last name, and e-mail address and password when you register for an Emtrey account, or information you provide if you correspond with us. We also collect any messages you send through the Service and may collect information you provide in User Content you post to the Service. If you place an order for the Service, our third-party payment processor will collect certain information including payment and billing details. When you are asked to provide information, you may decline. But if you choose not to provide information that is necessary for certain products or features, those products or features may not be available or function correctly.

Information collected automatically: When you use our Services, some information is collected automatically. For example, when you visit our websites, our web servers automatically log your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, the website you visited before our site, and your activity on our websites.

Cookies: When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser. We use cookies for a variety of purposes as described in this Privacy Policy including to help Emtrey log you in faster, enhance your navigation through the site, remember your preferences and settings, advertising and analytics, combat fraud, analyze how our products perform, and fulfill other legitimate purposes. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

Clear GIFs & web beacons: We may use clear images on our websites or in our emails sent to our users. We use web beacons to help us deliver cookies on our websites, count users who have visited those websites, gather usage and performance data, and to track which emails are opened and which links are clicked by recipients.

Third-party analytics and advertising: Our websites may include web beacons and cookies from third-party service providers. In some cases, that is because we have hired the third party to provide services on our behalf, such as site analytics. In other cases, it is because our web pages contain content from third parties. Because your browser connects to those third parties’ web servers to retrieve that content, those third parties are able to set or read their own cookies on your device and may collect information about your online activities across websites or online services.

The third-party analytics providers we use include: Google and MixPanel. Many third-party analytics providers allow you to opt-out from their collection or use. For more information, click on the links above.

Our third-party advertising partners include: Google, Twitter, and LinkedIn. You may find more information on each company’s practices, including the choices it offers, by clicking on the above. Many of them are also members of the Network Advertising Initiative (NAI) or Digital Advertising Alliance (DAA), which each provide a simple way to opt out of ad targeting from participating companies., which you can access at https://optout.networkadvertising.org and https://optout.aboutads.info.

Third-party sources: We also obtain information from third parties. We protect information obtained from third parties according to the practices described in this policy, plus any additional restrictions imposed by the source of the information. These third-party sources include:

  • Applications and services, such as social networks, that make users’ information available to others;
  • Service providers that help us determine your device’s location based on its IP address to customize certain products to your location;
  • Partners with which we offer co-branded services or engage in joint marketing activities; and
  • Publicly-available sources, such as open government databases or other data in the public domain.

2. Use of Your Information

We use information collected through our products for purposes described in this Privacy Policy or otherwise disclosed to you. For example, we use your information to:

  • provide and deliver our Services and related products, including securing, troubleshooting, improving, and personalizing those products;
  • operate our business, such as improving our internal operations, securing our systems, and detecting fraudulent or illegal activity;
  • understand you and your preferences to enhance your experience and enjoyment using our products;
  • provide customer support and respond to your questions;
  • send you information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; and
  • communicate with you about new products, offers, promotions, and other information about our products and those of our selected partners (see the “Your Choices about your information” section of this Privacy Policy for how to change your preferences for promotional communications).

In carrying out these purposes, we combine information we collect from different sources to give you a more seamless, consistent, and personalized experience.

3. Sharing of Your Information

We share information with your consent, as necessary to complete your transactions and provide the Services you have requested or authorized, and as noted below:

Who we may share your information with: We share personal information among our affiliates and subsidiaries. We may also share your information with third-party business partners for the purposes described in this Privacy Policy. Those business partners will be given limited access to your information as is appropriate to deliver the Service or fulfill the purposes described in this Privacy Policy. In such cases, these companies must abide by data privacy and security requirements and are not allowed to use information they receive from us for other purposes.

What happens in the event of a change of control or other corporate transaction: We may buy or sell/divest/transfer Emtrey (including any shares in Emtrey), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, User Content and other user information related to the Service may be among the items transferred as a part of these types of transactions. We may sell, assign or otherwise transfer such information in the course of any kind of change of control transaction or in the event of a corporate divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, or similar transactions or proceedings involving all or a portion of Emtrey.

Other instances where we share your information: Emtrey will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Emtrey, our Users or others.

We may also share anonymous or aggregate data with third parties for any purpose.

4. How We Store and Protect Your Information

Retention: We retain information for as long as necessary to provide the products and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

Location and transfer: Your information collected through the Service may be stored and processed in the United States or any other country in which Emtrey or its subsidiaries, affiliates or service providers maintain facilities. Currently, we primarily use data centers in the United States. The storage locations are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps designed to ensure that the information we collect under this Privacy Policy is processed according to the provisions of this Privacy Policy and applicable law wherever the data is located.

We transfer information from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal information protections, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.

Keeping your information safe: Emtrey cares about the security of your information, and uses commercially reasonable safeguards designed to preserve the integrity and security of information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) designed to verify your identity before granting you access to your account. You are responsible for choosing a strong, unique password, maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Emtrey, at all times. However, Emtrey cannot ensure or warrant the security of any information you transmit to Emtrey or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third-party sites and services that you add to the Service, such as social networks. Emtrey is not responsible for the functionality or security measures of any third party.

5. Your Choices about Your Information

You control your account information and settings: You may update your account information and email-communication preferences at any time by logging into your account and changing your profile settings. If you cannot access certain information we collect as described above or directly through the Services, you can always contact us at hello@emtrey.io. However, to the extent permitted by applicable law, we reserve the right to charge a fee or decline requests that are unreasonable, excessive, or prohibited by law, could adversely affect the privacy or other rights of another person, or where we are unable to authenticate you as the person to whom the data relates.

Communication preferences: You can also request to stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. You may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at hello@emtrey.io.

Opting out of collection of your information through cookies: Please refer to your browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Most browsers are set to accept cookies by default. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your device. Disabling may disable many of the features available through the Service. See the “Information collected automatically” section of this Privacy Policy for more details.

Advertising and analytics: Our third-party analytics and advertising partners typically provide options to opt-out of certain information collection or use. See the “Information collected automatically” section of this Privacy Policy for more details.

Do Not Track: Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Our websites do not currently respond to browser DNT signals. Instead, you can use a range of other tools to control data collection and use, including the cookie controls and advertising controls described above.

6. European Data Protection Rights

If the processing of information about you is subject to European Union data protection law, you have certain rights with respect to that data:

  • You can request access to, and rectification or erasure of, certain information;
  • If any automated processing of information is based on your consent or a contract with you, you have a right to transfer or receive a copy of your information in a usable and portable format;
  • If the processing of information is based on your consent, you can withdraw consent at any time for future processing;
  • You can object to, or obtain a restriction of, the processing of information under certain circumstances; and
  • For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests, contact us at hello@emtrey.io. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

7. Links to Other Websites and Services

We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and we do not control over any third-parties that you authorize to access your User Content. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service.

8. How to Contact Us

If you have any questions, complaints, or concerns about this Privacy Policy or the Service, email hello@emtrey.io.

9. Changes to Our Privacy Policy

Emtrey may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner we will let you know and update the “Last Modified” date at the top of this page. If we make material changes to the Privacy Policy, we will provide notice or obtain consent regarding such changes as may be required by law.