Boss Report Card Privacy and Cookie Policy

January 30, 2019

We, Boss Report Card LLC as the data controller (“Boss Report Card,” “we,” or “us”), explain in this Privacy and Cookie Policy (the “Policy”) how we collect, process and/or use information that we receive via our websites, emails we send, and mobile applications (collectively, the “Platform”) that link to this Policy, as amended from time to time. This Policy describes how Boss Report Card collects, processes, uses, shares and secures the personal information you provide. It also describes your choices regarding use, access, and correction of your personal information. For purposes of this Policy, personal information shall mean any information relating to an identified or identifiable natural person.

This Policy applies only to information we collect, process, and use through the Platform. This Policy does not apply to information that we collect through other channels, such as information that we collect offline, from other websites or from emails you send us.

Information We Collect

We collect information about you to provide our services. In order for us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. This means that the data collection is largely necessary for fulfilling the relationship we have with you, and where that is not the case, we have a legitimate interest in collecting the information described below.

Information You Give Us

When you fill out registration forms or provide us with other personal information actively, we collect that information for processing and use in accordance with this Policy. Because we will change our offerings and features from time to time, the options you have to provide us with personal information also may change, but here are some examples of situations in which you will have the opportunity to provide personal information to us:

• Creating an account;
• Signing up for email alerts;
• Completing a form related to one of our products or services;
• Contacting us

Depending on how you interact with our Platform, the personal information we collect from you may vary. For example, to create an account we may ask only for an email address and password. In other circumstances, such as when you complete a form related to a particular service offering, we may ask you to provide other information, which may include your name and other personally identifying information. We also collect and store certain information associated with actions you take. We also store information about the time and duration of your activity on our Platform, and other information about your behavior on our Platform.

On certain Boss Report Card domains, when you set up an individual user account on the Platform, you may create a profile (a “Profile”) that will include personal information you provide. Because your anonymity on our Platform is important, your Profile does not include or link to information you submit to the Platform anonymously. But for our Platform you must not be logged in while making a review if you wish it to be entirely anonymous.

Information We Collect Automatically

When you use the Platform, your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect also may include usage information and statistics about your interaction with the Platform. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Platform.

Automated means of data collection include the following:

Log File Information

Log file information is automatically reported by your browser or mobile application each time you access a website on our Platform. For example, when you access a Boss Report Card website, our servers automatically record certain information that your web browser sends when you visit any website. These server logs include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.

Device Information

We collect information about the device you use to access the Platform, including type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. We collect the device type and any other information you choose to provide, such as username, geolocation, or email address. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

How We Use Information

We use the information we collect to provide our services. In order for us to best provide our services (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. So it is largely necessary for fulfilling the relationship we have with you, and, where that is not the case, we have a legitimate interest in using the information we collect, including personal information, for these purposes:

• to provide you with personalized content, services and offers of services offered by Boss Report Card, as well as other promotional content and services by affiliates. For the purposes of this Policy, “affiliates” means any entity that directly or indirectly, controls, is controlled by, or is under common control of or with Boss Report Card, LLC. now or in the future. “Control” for these purposes means having a majority of shares or the right and ability to direct management.
• to moderate and display the content you have submitted for the benefit of our other users;
• to customize and improve the features, performance, and support of the Boss Report Card site and sites of Boss Report Card affiliates;
• to communicate with you or initiate communication with you on behalf of third parties through your Boss Report Card account or through other means including through the use of contact information that you provide to us or (where it is lawful for us to do so);
• to permit Boss Report Card to contact Boss Report Card users with respect to such recommendations, subject to visibility settings you control;
• to provide relevant advertising, including interest-based advertising from us and third parties, which may mean that we share non-personally identifiable information to third-party advertisers;
• to allow Boss Report Card and Boss Report Card affiliates to process your personal data for the purpose of improving for internal operations, including detecting and preventing fraud and spam, troubleshooting, data analysis, testing, research, and service improvement (this includes use of your IP address and mobile device information to help diagnose problems with our service and to administer the Platform);
• to create aggregate and statistical data that does not identify you individually and that we can commercialize;
• for other purposes that you separately authorize as you interact with Boss Report Card.

When we collect any information that does not identify you as a specific natural person (“Non-Personal Information”), we are permitted to use and disclose this information for any purpose, notwithstanding anything to the contrary in this Policy, except where we are required to do otherwise by applicable law. Examples of Non-Personal Information include: physical location information; demographic information, including gender, dates of birth, ZIP codes, etc.; or any personal information that has been anonymized, aggregated or de-identified. If we combine any Non-Personal Information with your personal information (such as combining your ZIP code with your name), we will use and disclose such combined information as personal information in accordance with this policy. Similarly, if applicable law requires that we treat certain Non-Personal Information as personal information, we will use and disclose this information as personal information in accordance with this policy.

How We Share Information

We only disclose your personal information to third parties as follows:

• We use affiliated and unaffiliated service providers all over the world (including web servers, cloud storage systems, CRM providers, email services, content support teams, marketing partners, advertising partners, and others) to help us deliver our service and run our business subject to strict confidentiality agreements. These companies are authorized to use your personal information only as necessary to provide these services to us;
• We may also share your information with Boss Report Card affiliates, namely any entity that directly or indirectly controls, is controlled by, or is under common control with Boss Report Card. Such affiliates shall process your personal data where we believe it is necessary for the purposes of a legitimate interest, and where such purposes are aligned with those for which you provided your personal data to us.
• We will disclose data If we believe in good faith such disclosure is necessary (1) to comply with relevant laws or to respond to subpoenas or warrants or legal process served on us (though we reserve the right to take action on behalf of our users to defend their right to anonymity when we believe there is a legitimate basis to do so, because candid, lawful, anonymous free speech is fundamental to Boss Report Card’s mission of transparency); (2) to enforce our Terms of Service and Privacy Policy when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; (3) as we otherwise deem necessary and is permitted by applicable laws to protect and defend the rights or property of us, the users of our services, or third parties; or (4) as permitted under applicable laws to meet national security and similar requirements;
• In reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer and its affiliates accepting the commitments made in this Policy and compliance with applicable law;
• We share certain information that does not identify you personally, but which is unique to your use of the Platform. When we share such information, we do not link anything with your name when we provide this information to others, such as advertisers;
• We will otherwise share personal information with your consent.

Cookie Policy

Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive.

Our website uses these “cookies” to collect information and to improve our Service. You have the option to either accept or refuse these cookies, and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our Service.

Do Not Track Signals

We do not currently respond to ‘do not track’ signals and similar settings or mechanisms. When you use the Platform, we try to provide a customized experience.

How Long We Keep Your Personal Information

We keep your personal information only so long as we need it to provide the Platform to you and fulfill the purposes described in this Policy. This is also the case for anyone that we share your personal information with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can’t identify you.

Security Safeguards

We employ physical, electronic, and managerial measures to safeguard the information we collect online. However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. You are responsible for keeping your username and password secret. Once you have registered with us, we will never ask you for your password. Please create a unique password for your Boss Report Card account and do not use it for any other web services or applications. Do not share your password with anyone else.

If you think you have been the victim of fraud, immediately report the fraud to your local police and contact Boss Report Card

Privacy of Minors

To access or use the Platform you must be at least 16 years of age or, if older, the age of majority in your jurisdiction, otherwise you may not use the Platform. If you become aware that a child has provided us with personal information without parental consent, please contact us. If we become aware that a child has provided us with personal information without parental consent, we remove such information and terminate the child’s account.

Updates to Our Privacy Policy

We may revise this Policy from time to time by posting an updated version on the Platform. The revised Policy will be effective immediately for unregistered users and users registering accounts or otherwise acknowledging the Policy on or after the revision date. For other users who registered accounts before the revision date, it will also become effective immediately. However they can object to the new Policy within thirty (30) days after the revision date. If we make a change that we believe materially reduces your rights or increases your responsibilities, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We may provide notice of changes in other circumstances as well. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Platform is subject to the most current effective version of this Policy. If you object to the Policy after it becomes effective for you, you may no longer use the Platform.