Privacy Policy

Last updated: September 20th 2021.

In this Privacy Policy (“statement”), we, Gotransverse LLC, provide information about how we collect, use, disclose, and transfer Personal Information from you, an individual person and website visitor, through Gotransverse’s publicly accessible websites.

This statement outlines our general policy and practices for implementing the Privacy Shield Principles including the types of information we gather, how we use it, and the notice and choice affected individuals have regarding our use of and their ability to correct that information.

This statement applies to all Personal Information collected or received by Gotransverse through our website and the Gotransverse platform.

We have updated our prior Privacy Policy to reflect that we no longer rely on the EU-U.S. and Swiss-U.S. Privacy Shields as a basis under the EU General Data Protection Regulation (GDPR) for the transfer of Personal Data from the EU, UK, and Switzerland to the United States.

Gotransverse still complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and Switzerland to the United States. Gotransverse has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. Gotransverse commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Definitions

“Account” means a unique account created for you to access our Service or parts of our Service.

“Data Controller”, for the purposes of the GDPR (General Data Protection Regulation), data controller refers to Gotransverse’s customer as the legal entity which alone or jointly with others determines the purposes and means of the processing of Personal Data.

“Data Processor” means an entity which processes Personal Data on behalf of the Data Controller and to which another entity discloses a natural individual’s Personal Information for a business purpose pursuant to a written contract that requires the entity receiving the information to only retain, use, or disclose Personal Data information for the purpose of providing the Services.

“GDPR” means the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data);

“Personal Data” is any information that relates to an identified or identifiable individual.

“Personal Information” “Personal Data” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, or that concerns an individual’s health.

Collecting and Using Personal Data

What types of Data are Collected or Received?

Personal Data. The following types of Personal Information may be collected or received for various purposes, including identifying users of the Gotransverse platform services and to better serve the users such as for billing and subsequent payment processing for the services consumed. Personally identifiable information may include, but is not limited to:

  • Name
  • Address
  • Email address
  • Phone number
  • Company Name
  • Title
  • Demographic information such as post-code, preferences, and interests
  • Payment Information (billing name, address, and credit card information)
  • Other information relevant to customer surveys and/or offers

Additional information such as business or organization name, type of business, number of employees, annual revenues, cash balances, and related financial information may be collected.

What we do with the information we gather?

Information collected through our websites is used to understand your needs and provide you with better service, and in particular for the following reasons:

  • Internal record keeping
  • To improve our products and services including our websites to suit to your interests and needs
  • Send promotional emails about new products, special offers, or information you may find interesting from us or our partners
  • To conduct market research
  • To fulfill contracted services to our customers

The information collected or received through the Gotransverse platform is used only to fulfill the functions and services subscribed to via the platform. We do not share this information with outside parties except to the extent necessary to fulfill the services. These third parties consist of service providers and may access, process, or store Personal Data in the course of providing their services. Gotransverse maintains contracts with these third-party services restricting their access, use, and disclosure of Personal Data in compliance with our Privacy Shield obligations, and Gotransverse may be liable if they fail to meet those obligations and we are responsible for the event giving rise to damage. Gotransverse also reviews compliance documentation from these third-party services annually to verify proper security controls are in place, followed, tested and verified by certified third-party auditing firms.

Email or personal or business addresses are not used for any other purpose and are not shared with outside parties.

How is information gathered?

Information is sent to the Gotransverse platform by the Data Controller via encrypted key-protected API or entered manually by the Data Controller using our secure user interface.

Retention and Destruction of data

Gotransverse’s customer data is destroyed 60 days after the contractual relationship with the customer (Data Controller). If a request is not made to remove individual Personal Data, Gotransverse will retain the data and process on behalf of our customers for as long as needed to provide services to our customers. We will retain and protect this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Transferring of Personal Data

Gotransverse is a U.S. based, global company and will never transfer information out of the country where the data resides. All data is replicated and backed up to a geographically distant location within the borders of the same country.

Disclosure of Personal Data

Gotransverse reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

If Gotransverse is involved in a merger, acquisition or asset sale, Personal Data may be transferred. Notice will be provided before any Personal Data is transferred and becomes subject to a different Privacy Policy.

Sharing of information

Gotransverse will never use or share the Personal Information collected or received in ways unrelated to the ones described above without also providing an opportunity to opt-out or otherwise prohibit such unrelated uses. Gotransverse will never sell your information to anyone whosoever.

How is information protected?

Protecting customer data is at the forefront of what we do which is why we have a proactive approach to Privacy. Gotransverse has integrated data protection and privacy features not only into their system engineering, but into their practices and procedures. It has never been an afterthought or a supplement to our processes or infrastructure. End-to-end security in that privacy protection follows data through the lifecycle (collection, processing, storage, & backup). Encryption and multi-factor authentication are the standard at every stage.

Privacy by Design can best be explained by defining it as “data protection through technology design.” Privacy is imbedded into our design and architecture.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which Gotransverse is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in Gotransverse
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by Gotransverse

In any case, Gotransverse will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

  • Request access to your Personal Data. The right to access, update or delete your Personal Information. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact Us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
  • Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for Our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request erasure of your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for Us to use or where we used the information to perform a contract with you.
  • Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the the Data Controller.

If requested to remove personally identifiable data, it is on the part of the Data Controller to make the change within their system and either 1) utilize their user interface to make the same changes to the corresponding account in the Gotransverse system or, 2) send a request to Gotransverse to make the changes to the billing account.

Exercising of your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, Gotransverse will try our best to respond to you as soon as possible.

Because of the complex architecture of the Gotransverse Billing Platform, deletion of accounts will result in the inaccuracy of records, statements, invoices, ledgers, etc. To circumvent this issue, an account will be considered removed if the user is no longer identified as being in the system. Changing of personally identifiable information (First & Last Name, Home Street Address, billing street address, Phone Number, E-mail address) will make a user’s identity obsolete in the system. This includes history and future transactions.

You have the right to complain to a Data Protection Authority about Our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

The Gotransverse platform collects information under the direction of our customer and has no direct relationship with the individuals whose personal data it processes. If you are an end user of one of our customers and would like to remove your data from their system or would no longer like to be contacted by one of our customers that use our service, please contact the customer that you interact with directly. While unlikely, Gotransverse may transfer Personal Information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.

Gotransverse Websites

Should we ask you to provide certain information by which you can be identified when using our websites, you can be assured that it will only be used in accordance with this privacy statement.

Notice to UK and EU Residents

Please note that the “Personal Information” referenced in this Privacy Policy means “Personal Data” as that term is defined under the European Union (“EU”) General Data Protection Regulations (“GDPR”) and its United Kingdom (“UK”) GDPR counterpart. Gotransverse is a Data Processor for the Personal Data collected from Data Controllers and processes the Personal Data of end users on behalf of its customers.

If you are an individual from the European Economic Area (the “EEA”), the UK or Switzerland, please note that our legal basis for collecting and using your personal information will depend on the personal information collected by its customers and the specific context in which they collect it.

Cookie Policy

Cookies are small text files that are stored in a computer’s web browser memory. They help website providers with things like understanding how people use a website, remembering a user’s login details, and storing website preferences. This page explains how we use cookies and other similar technologies to help us ensure that our Services function properly, prevent fraud and other harm, and analyze and improve the Services.

How we use cookies

Cookies help us provide effective web experiences. We change the cookies periodically as we improve or add to our Services, but we generally use cookies for the following purposes:

  • Cookies help us understand how to make our website and services work better for you. Cookies tell us how people reach our website and our users’ websites. They give us insights into improvements or enhancements we need to make to our website and services.
  • Cookies can help us provide more effective advertising. For example, we might use a cookie to help prevent you from seeing the same advertisement multiple times or to measure how many times an advertisement is viewed or clicked on.
  • We use Google Analytics, which uses cookies and similar technologies, to collect and analyze information about the use of the services, and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices on the Google website.
  • Additionally, the Gotransverse platform uses cookies to track session status to authenticate user accounts. These cookies are only used by the platform and are not used in conjunction with other cookies on our website.

How to manage cookies

Your web browser should allow you to change your cookie preferences, including to delete and disable Gotransverse cookies. Please consult the help section of your web browser or follow the links below to understand your options, but please note that if you choose to disable the cookies, some features of our website or services may not operate as intended.

Forms

By submitting forms on the gotransverse.com domain you agree to our privacy policy and you acknowledge that you want to receive relevant marketing materials from us. We do not share or sell your data/email address with any 3rd party services.

You may opt-out of any emails by visiting – https://gotransverse.com/unsub...

You may also request any data we have on you as well as be deleted from our marketing database.

Links to other websites

Our websites may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over the linked website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide while visiting such sites.

Such sites are not governed by this privacy statement and may or may not be compliant with privacy laws. You should exercise caution and look at the privacy statement, if available, of the website in question.

Controlling your personal information on our websites

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to us at, Gotransverse, 600 Congress Ave, Suite 2800, Austin, TX 78701, or emailing us at info@gotransverse.com

You may request details of personal information which we hold about you under the Data Protection Act, 1998. If you would like a copy of the information held on you, please write to the address above. A small fee may be payable.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, using the contact information provided above. We will promptly correct any information found to be incorrect.

Data Security

We employ several preventive, detective, and corrective technology and processes to safeguard information from attackers. These safeguards help prevent unauthorized access, maintain data privacy, and ensure the appropriate use of data.

The Gotransverse platform requires unique usernames and passwords that must be entered each time a customer logs on. Any information entered into the Gotransverse platform is encrypted using transport layer security (TLS).

Data Integrity

We only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by our customers. To the extent necessary for those purposes, we take measures to ensure that Personal Information is accurate, complete, current, and reliable for its intended use.

See the section above regarding “Controlling your personal information” for details on how to restrict or obtain a copy or correct your personal information we may hold.

Enforcement

We use a self-assessment approach to assure compliance with this statement and periodically verify that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Privacy Shield Principles. In compliance with the Privacy Shield Principles, Gotransverse commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Gotransverse via mail at:

Gotransverse LLC, 600 Congress Ave, Suite 2800, Austin, TX 78701 Attn: Data Privacy

Gotransverse has further committed to refer unresolved Privacy Shield complaints to JAMS an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-...; for more information or to file a complaint. The services of JAMS are provided at no cost to you. If neither Gotransverse nor our dispute resolution provider resolves your complaint, you may have the possibility to engage in binding arbitration through the Privacy Shield Panel.

Reporting Security Incidents

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us here.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. Gotransverse will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Effective Date: September 20th, 2021.

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