Sides LLC (“Sides”, “we”, “us” or “our”) is committed to protecting the privacy of personal information (i.e. any information relating to an identified or identifiable natural person) who visit the https://sides.legal website and Sides mobile software application (collectively, the “Site”) and use the services available thereon (the “Services”). Amendments to this Privacy Policy will be posted to the Site and/or Services and will be effective when posted. Your continued use of the Site and/or Services following the posting of any amendment to this Privacy Policy shall constitute your acceptance of such amendment.
When you register as a user of our Site and Services, we ask for personal information that will be used to activate your account, provide the Services to you, communicate with you about the status of your account, and for other purposes set out in this Privacy Policy. Your name, company name, address, telephone number, email address, credit card information and certain other information about you may be required by us to provide the Services or be disclosed by you during your use of the Services. You will also be asked to create a user name and private password, which will become part of your account information.
By providing personal information to us and by retaining us to provide you with the Services, you voluntarily consent to the collection, use and disclosure of such personal information as specified in this Privacy Policy. The legal bases for our processing of personal information are primarily that the processing is necessary for providing the Services and that the processing is carried out in our legitimate interests, which are further explained below. Without limiting the foregoing, we may on occasion ask you to consent when we collect, use, or disclose your personal information in specific circumstances.
Our Site collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked to, directly or indirectly, with a particular consumer or device (“personal information”). The information may be provided through the following sources:
In particular, our Site has collected the following categories of personal information from its consumers within in the last 12 months:
| Category | Examples | Collected |
| A. Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | Yes |
| B. Personal information | categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information in this category may overlap with other categories. | Yes |
| C. Protected classification | under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | No |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait or other physical patterns, and sleep, health, or exercise data. | No |
| F. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Yes |
| G. Geolocation data | Physical location or movements. | Yes |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or other similar information. | No |
| I. Professional or employment-related information | Current or past job history or performance evaluations. | Yes |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 24 C.F.R. Part 99) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | No |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | No |
We take steps designed to ensure that only those employees who need access to your personal information to fulfill their employment duties will have access to it. We may use or disclose your personal information for the following purposes:
Sides will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may also use your personal information to generate Aggregated Data for internal use and for sharing with others on a selective basis. “Aggregated Data” means records which have been stripped of information potentially identifying users, and which have been manipulated or combined to provide generalized, anonymous information. Your identity and personal information will be kept anonymous in Aggregated Data.
Sides may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We also take reasonable measures to ensure that these third parties provide sufficient guarantees to implement appropriate technical and organizational measures.
We share your personal information with the following categories of third parties:
In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
In the preceding 12 months, we have sold the following categories of personal information for a business purpose:
Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using the Services, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of the United States, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Privacy Policy and, if applicable, we will comply with the General Data Protection Regulation (“GDPR”) requirements providing adequate protection for the transfer of personal information from the EU/EEA to third country.
We may occasionally communicate with you regarding our products, services, news and events. You have the option to not receive this information. We provide an opt-out function within all email communications of this nature, or will cease to communicate with you for this purpose if you contact us and tell us not to communicate this information to you. The only kind of these communications that you may not “opt-out” of are those required to communicate announcements related to the Services, including information specific to your Account, planned Services suspensions and outages. We will attempt to minimize this type of communication to you.
We do not knowingly provide the Services to, and will not knowingly collect the personal information from anyone under the age of consent. If you live in a country in the EU/EEA, you must be at least 16 years old to use our Services or such greater age required in your country to register for or use our Services. If you live in any other country except those in the EU/EEA, you must be at least 13 years old to use our Services or such greater age required in your country to register for or use our Services. In addition to being of the minimum required age to use our Services under applicable law, if you are not old enough to have authority to agree to our Privacy Policy in your country, your parent or guardian must agree to our Privacy Policy on your behalf. If you have any concerns about your child’s personal information, please contact us at help@sides.legal.
Neither the Site nor the Services are intended for children under 13 years of age, and no one under age 13 may provide any personal information to, on or through the Site or Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information to, on or through the Site or Services, make any purchases through the Site or Services, use any of the interactive or public comment features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the email address provided in the paragraph above.
You have the right to access and edit your information at any time through the web interface provided as part of the Services. On written request and subject to proof of identity, you may access the personal information that we hold, used or communicated and ask that any necessary corrections be made, where applicable, as authorized or required by law. However, to make sure that the personal information we maintain about you is accurate and up to date, please inform us immediately of any change in your personal information by mail or e-mail.
Under the GDPR, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your personal information and certain other supplementary information, under certain conditions; (iii) the right to object to unlawful data processing, under certain conditions; (iv) the right to erasure of personal information about you, under certain conditions; (v) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your personal information is inaccurate; (vi) the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection.
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
To exercise the access, data portability, and deletion rights, please submit a verifiable consumer request to us by emailing us at help@Sides.legal. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12 month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable request does not require you to create an account with us.
We endeavor to respond to verifiable consumer requests within 45 days of receipt. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response to you by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If applicable, we will also provide reasons we cannot comply with your request. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information. We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or unfounded. If we determine a fee is warranted, we will provide you with an estimate before completing your request.
If you are 16 years of age or older, you have the right to direct us not to sell your personal information (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years or age, or the parent or guardian of a consumer less than 13 years of age. Consumers may opt-out of future sales at any time. To exercise the right to opt-out, you should not use the Services, as we are not technically able to ensure that your personal data will not be “sold” (as we currently understand that term to be defined under the CCPA).
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
California Civil Code Section §1798.83 permits users of the Site and/or Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to help@Sides.legal with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you in your email address in response.
The Site and/or Services may contain links to other sites and we are not responsible for the privacy practices or the content of such sites. We encourage you to read the privacy policy of linked sites. Their privacy policies and practices differ from our policies and practices.
We use cookies and log files to track user information. Cookies are small amounts of data that are transferred to your web browser by a web server and are stored on your computer’s hard drive. We use cookies to track which page variant a visitor has seen, to track if a visitor has clicked on a page variant, to monitor traffic patterns and to gauge popularity of service options. We will use this information to deliver relevant content and services to you.
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 (“NAI”) on the NAI’s website.
In the event of a change of ownership or other business transition, such as a merger, acquisition or sale of our assets, your information may be transferred in accordance with applicable privacy laws.
We will strive to prevent unauthorized access to your personal information, however, no data transmission over the Internet, by wireless device or over the air is guaranteed to be 100% secure. We have implemented and maintain reasonable security procedures and practices (based on the nature of the information we collect) to protect that information from unauthorized disclosure. We will continue to enhance security procedures as new technologies and procedures become available.
We strongly recommend that you do not disclose your password to anyone.
Please remember that you control what personal information you provide while using the Site and Services. Ultimately, you are responsible for maintaining the secrecy of your identification, passwords and/or any personal information in your possession for the use of the Site and/or Services. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the personal information you provide to others through the Site or Services. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through the Site or Services, and you release us from any and all liability in connection with the contents of any personal information or other information which you may receive using the Site or Services. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the personal information or other information provided by any third party. You release us from any and all liability in connection with the use of such personal information or other information of others.
We will maintain your personal information for as long as they are needed, or as required by applicable laws, regulations, or government orders.
We may update this Privacy Policy from time to time. If we do so, we will send an email to users subscribed to the Sides Communication list. We will also add a site banner alerting users who may not be subscribed. If the change materially effects the treatment of your personal data, and we have your email but you are not subscribed to the Company News list, we will send you an email. (You are responsible for ensuring that we have an up-to-date email for this purpose.)
If you have any questions or comments about this Privacy Policy or your personal information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers outside th United States, our Privacy Officer (or Data Protection Officer) can be reached by mail or email using the following contact information: by email at help@Sides.legal.
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