Etch Mobile d/b/a GoodTime.io (“GoodTime”) Consolidated Privacy Notice
Last Updated: October 28, 2024
GoodTime, along with its affiliate and subsidiary companies, (“GoodTime,” “we,” “us,” or “our”) provides our customers with electronic information technology and calendaring and communications services. This GoodTime Technologies Consolidated Privacy Notice (the “Privacy Policy”) is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.
This Privacy Policy applies to personal information processed by us, including on our websites, products, services, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, services, and other offerings are collectively referred to as the “Services.”
An Important Note: This Privacy Policy does not apply to personal information that our customers, along with their employees, contractors, and other personnel (collectively, “Workers”) provide to us to process on the customer’s behalf (collectively, “Customer Data”). Rather, our customers’ respective privacy policies (such as their employee privacy notices) govern their collection and use of Customer Data, and our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy.
Any questions or requests relating to Customer Data should be directed to our customers.
The categories of personal information we collect as a data controller depend on how you interact with our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
A. Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
B. Information Collected Automatically
We may collect personal information automatically when you use our Services:
C. Information Collected from Other Sources
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.
With respect to the personal information we process, we use this information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
A. Provide Our Services
We use your information to fulfill our contract with you and provide you with our Services, such as:
B. Administrative Purposes
We use your information for various administrative purposes, such as:
C. Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and advertisements for our Services. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audiences advertising, and interest-based or personalized advertising, including through cross-device tracking. If you have any questions about our marketing practices, or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
D. Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law and with respect to the data we control, you may have the right to:
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We have taken appropriate safeguards to protect your personal information, and take steps to require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you reside. We endeavor to safeguard your information consistent with the requirements of applicable laws.
We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information GoodTime has collected about them and whether GoodTime disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months, which may be disclosed to subprocessors/third parties found at goodtime.io/subprocessors. California residents can find this information below:
GoodTime Hire | |
Candidates |
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Employees |
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ATS Data |
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Interviews |
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Emails sent from GoodTime |
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Rooms (resources) |
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Company data |
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Integrations |
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GoodTime Meet | |
Guest |
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Users |
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Rooms (resources) |
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Company Data |
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Data Passed Back into Cloud |
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Marketing Information | |
Commercial information |
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Internet or other electronic network activity |
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The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.
“Sales” of Personal Information under the CCPA
For purposes of the CCPA, GoodTime does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age, as the term “sell” is commonly understood. That said, we do share information with third-party advertisers for the purpose of promoting our Services. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your information shared by disabling third-party cookies on your device, or by contacting us as set forth in “Contact Us” below.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized 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. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.
Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.
California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at legal@goodtime.io with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our Services without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.
As of July 16, 2020, the European Court of Justice issued a judgment declaring Privacy Shield invalid. We now rely on other transfer mechanisms, such as the SCCs (standard contractual clauses) described above under “Transferring Information to the US”, for the cross-border transfer of data.
Prior to the invalidation of Privacy Shield, we relied on our Privacy Shield certification to transfer personal data from Europe to the US. As noted above, we currently rely on the SCCs (standard contractual clauses). We process this data in accordance with the Privacy Shield principles of Notice and Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability, as described below.
GoodTime complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. GoodTime has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. GoodTime has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit the Data Privacy Framework site..
A. Notice
When we collect Personal Data directly from individuals in the EU, UK, Switzerland and/or other applicable countries, we will inform them about the purposes for which we collect and use their Personal Data, the types of third parties (other than Agents), if any, to which we disclose that information, and the choices and means, if any, that we offer individuals for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to us, or as soon as practicable thereafter, and in any event before we use the information for a purpose other than that for which it was originally collected. If we receive Personal Data from our affiliates or other entities in the EU, Switzerland and other countries with which we do business, we will use such information in accordance with the notices such entities provided and the choices made by the individuals to whom such Personal Data relates.
B. Choice
We will offer individuals the opportunity to choose (opt-out) whether their Personal Data is (a) to be disclosed to a third party (other than an Agent), or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Data, we will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to (a) the disclosure of the information to a third party, or (b) the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. We will provide individuals with reasonable methods to exercise their choices. We may disclose personal information to third parties in the following instances:
Enforcement of Rights / Security. We reserve the right to release personal information (i) when we are under legal compulsion to do so (e.g. we have received a subpoena) or we otherwise believe that the law requires us to do so, (ii) when we believe it is necessary to protect and/or enforce the rights, property interests, or safety of us, our customers or others, or (iii) as we deem necessary to resolve disputes, troubleshoot problems, prevent fraud.
As Otherwise Allowed by Law. We may transfer personal information to third parties where we are expressly authorized by applicable law to do so. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
C. Accountability For Onward Transfers
We will obtain assurances from our Agents that they will safeguard Personal Data consistently with this policy. If we have knowledge that an Agent is using or disclosing Personal Data in a manner contrary to this policy, we will take reasonable steps to prevent or stop the use or disclosure.
D. Access
Upon request, we will grant individuals reasonable access to Personal Data that we hold about them, and we will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
E. Resource, Enforcement And Liability
We will conduct compliance audits of our relevant privacy practices to verify adherence to this Policy. Any employee that we determine is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.
F. Investigations and Enforcement
We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
G. Recourse and Liability
Data Subjects may file a complaint concerning GoodTime's Processing of their Personal Data. The complaint should be sent to privacy@GoodTime.com. GoodTime will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of Personal Data within 45 days of receiving a complaint. For any unresolved complaints, GoodTime commits to cooperate with the EU data protection authorities. A Data Subject may submit its complaint to the appropriate resolution panel of the responsible data protection agency (DPA). GoodTime will ensure that a Data Subject does not incur any costs in its application to the DPA. The decision of the DPA shall be binding upon GoodTime. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm.
If a EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) complaint cannot be resolved through the above channels, under certain conditions, a Data Subject may invoke binding arbitration for claims not resolved by other redress mechanisms. In certain circumstances, the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles.
Should GoodTime become subject to an FTC or court order based on non-compliance with the Principles, GoodTime will make public any relevant EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles-related sections of any compliance or assessment report submitted to the FTC, to the extent consistent with confidentiality requirements.
H. Third Party Transfers. We may transfer Personal Data to our third-party agents, resellers, licensees, or service providers who perform functions on our behalf or on behalf of our customers as described in our policies. Where required by the DPF Principles , we enter into written agreements with those third-party agents, resellers, licensees, and service providers requiring them to provide the same level of protection the DPF Principles require and limiting their use of the data to the specified services provided on our behalf or on behalf of our customers. We take reasonable and appropriate steps to ensure that third-party agents, resellers, licensees, and service providers process Personal Data in accordance with our obligations under the DPF Principles and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents, resellers, licensees, or service providers who perform services on our behalf or on behalf of our customers for their handling of Personal Data that we transfer to them.
I. Complaints
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, GoodTime commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.
Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom, or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
Changes to our Privacy Policy. We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
Our AI Tools utilize advanced generative pre-trained transformer language models, (the “Language Models”), to deliver high-quality, human-like text generation based on user prompts and messages. This section outlines how we safeguard your personal data when you interact with our AI Tools:
Data Collection and Use:
Data Storage and Security:
Data Anonymization:
User Control and Consent:
Third-Party Access:
User Rights:
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:
Data Protection Officer
440 North Barranca Avenue #4198
Covina, CA 91723
privacy@goodtime.io
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