Last update: 05/01/2023
Satori (“us,” "we," or “our”) is committed to protecting and respecting your privacy in connection with your use of our website, www.satoriinsurtech.com
.We will acquire consent from you in order to use such trackers or provide you with the opportunity to opt-out of such trackers, to the extent required by applicable law. MOBILE ANALYTICSWe use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record data such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.LOG FILESAs true of most websites, we gather certain data and automatically and store it in log files. This data may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.6. WHERE WE STORE YOUR PERSONAL DATAAll data you provide to us through the Products is stored in our infrastructure hosted on AWS. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that your change your password frequently.Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Products; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.7. CORPORATE AND OTHER COMMUNITY SHARINGSatori is also offered through partnerships with organizations. Sometimes corporations, governments, hospitals, universities and other organizations and groups (“Partner(s)”) wish to make Satori available to their members, employees and their families, patients, customers, residents or others. For example, employers may offer their employees and their families access to Satori and brands that promote wellness may wish to and do offer Satori through their loyalty programs. When an entity provides access to Satori to others, we call those “Communities.” If you have registered to use the Products through a code, credential, or other means of registration furnished by a Partner (a “Community Subscription”), the Partner may have access to your name, email address, the date you registered to use the Products, and the date on which you last used the Products. The Partner may also have access to your Community's aggregated and anonymized general usage data (including aggregated and anonymized usage data with respect to your Community’s engagement).8. SINGLE SIGN-ONYou may be able to log-in to our Products using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal data (such as your name and email address) with us, and to pre-populate our sign-up form. Services like Facebook Connect give you to the option to post data about your activities on our Products or to your profile page to share with others within your network.9. YOUR DATA RIGHTSAs you may know, a European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom exercise those rights. As required under applicable law, the rights afforded to you are: A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof. A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, Satori will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and Satori may have legal or legitimate grounds for keeping such data.A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.A right to data portability: you have the right to receive the personal data concerning you which you have provided to Satori, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from Satori. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of Satori. Satori may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by managing your privacy preferences by logging in to your Satori account.A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about Satori’s personal data protection practices.A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give Satori instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email firstname.lastname@example.org. You may access your personal data to modify or update at any time via an online account, or by emailing email@example.com. We will respond to your request in a reasonable timeframe in accordance with applicable law.10. LEGAL BASES OF PERSONAL DATA PROCESSINGIn accordance with GDPR, Satori provides the following information regarding its Article 6 legal bases for personal data processing: The performance of the contract (the Satori Terms and Conditions) between you and Satori for the data processing relating to your use of Satori’s Products (including your orders and payments);Satori’s legitimate interest, more specifically:Our business interest in providing you with emails and push notifications for timely introductory materials and information about your Satori account, our Product features and updates, and offers to upgrade your free account to a subscription account.Our business interest in offering you particularized or adapted content based on your usage of the Products.Our business interest in recognizing you when you return to our Website and allowing us to speed up your searches. Our business interest in collecting data regarding your general usage activities for the purpose of improving our Satori user experience.Our business interest in requesting that you partake in Product surveys in order to better understand your needs and expectations.Our financial interest in providing you the opportunity to purchase Satori subscriptions for the benefit of a third party through the Satori “gifting” program.Our business interest in providing you the opportunity to invite another friend/contact to Satori and share information about your Satori activities with your friends and contacts.Our business interest in providing you with customer service communications regarding your account, questions about our content offerings, or any other matters directed to customer service staff, in order to have clear and easy communication with you and to respond to all your requests.Our business interest in estimating our audience size and usage patterns. Our business interest in collecting data related to unplanned downtime or errors in the Products.Our business interest in complying with our legal obligations, such as maintaining accurate financial records.Our business interest in verifying your eligibility in a Community and providing limited reporting to Partners associated with such Community, as further described in section 6.11. DISCLOSURE OF YOUR DATAWe may disclose your personal data to third parties as follows:In some circumstances, we may need to disclose your personal data to our subsidiaries, affiliates, contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them. In some circumstances, based on your specific requests, we may need to disclose your personal data to a third party so that it can provide a service you have requested from such party, or fulfill a request for data from such party. An example of this is the SMS Service.In some limited circumstances, we may disclose the personal data that you have provided to Satori to a third party that offers and/or provides goods or services complementary to our own for the purpose of enhancing our users’ experiences by offering you integrated or complementary functionality, complementary services or bundled pricing options.In some limited circumstances, our email service provider may receive certain information you share in-app to provide you with personalized email communications.If Satori’s service providers (like hosting, IT maintenance, market analytics, and payment service providers) require this data to provide services to Satori, Satori may disclose your personal data to such service providers, provided that each of such service provider to agree to maintain the confidentiality and security of your personal data in accordance with applicable law.If we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets, provided that the prospective seller or buyer agrees to maintain the confidentiality and security of your personal data in accordance with applicable law.If Satori is acquired by a third party, personal data held by us about our customers will be one of the transferred assets.If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of Satori, our customers, or others, we may disclose such personal data in accordance with such obligation. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.We may disclose your personal data to enforce or apply our Terms & Conditions, at https://www.satoriinsurtech.com/terms-and-conditions
, and other agreements, including for billing and collection purposes. We may disclose your personal data with your Community, if your subscription is a Community Subscription, as described under Corporate and Other Community Sharing above.We may disclose your personal data with third parties, such as Facebook, in order to serve Satori advertisements on such third-party platforms, to the extent that you have consented to or have been provided with notice of, and an opportunity to opt-out of, such practices under applicable law.We may disclose your personal data to fulfill the purposes for which you provide it, for any other purpose disclosed by us when you provide the information or for any purpose with your consent. 12. DATA RETENTIONThe retention periods applied by Satori comply with applicable legislation in effect on the date hereof, namely:For data relating to your account: such data will be permanently and irrevocably anonymized in the event that your account is: (i) inactive for a period of two (2) years; and (2) not subscribed to Satori. Moreover, we will permanently and irrevocably anonymize your account data within thirty (30) days of your written request to do so via email to firstname.lastname@example.org.For transactional data relating to your purchases: such data is kept for the entire period of the contractual relationship, then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not by Satori.For data collected based on your consent to receive our marketing communications: we will use such data until you opt out, withdraw consent or applicable law requires that such data is no longer used.When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months. Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.13. WITHDRAWAL OF CONSENT FOR PROCESSING ACTIVITIESTo the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing email@example.com. LINKS TO THIRD PARTY SITESThe Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative at it’s website
. However, please know that we don’t currently sell data triggering that statute’s opt-out requirements. 21. Accessing and Correcting Your InformationYou can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an email at firstname.lastname@example.org
to request access to, correct or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Proper access and use of information provided on the Website is governed by our Terms & Conditions, at https://www.satoriinsurtech.com/terms-and-conditions