Revised June 27, 2023
Purpose and Scope
ReCourses, Inc. dba Punctuation, including its subsidiaries and affiliates (collectively, “Punctuation,” “we,” or “us“) respects the privacy of individuals.
This Services Privacy Statement (“Services Notice”) applies to our collection, use, and disclosure of information obtained in connection with the provision and use of our hosted software applications and Mobile Applications (collectively, the “Subscription Service“), and related support services (“Support Services“), as well as professional services, including training and certification (the “Professional Services“) that we provide to Customers (defined below). In this Services Notice, the Subscription Service, Support Services, and the Professional Services are collectively referred to as the “Service.”
This Services Notice does not apply to a Customer’s use or disclosure of any information it stores in the Subscription Service. This Services Notice also does not apply to information or data collected by Punctuation for other purposes outside of or unrelated to the Service. Please see our Website and Event Privacy Statement for details on our privacy practices with respect to data collected on our websites and at events.
For the purposes of this Services Notice:
- “Customer” means the entity that purchases our Service.
- “Customer Agreement” means the definitive agreement between Customer and Punctuation pursuant to which the Customer purchased access to the Subscription Service.
- “Customer Data” means the electronic data uploaded into the Subscription Service by or for Customer or its Users.
- “Account Data” means a Customer or Partner’s name and address, credit card or billing information, and the Customer or Partner representatives’ contact information.
- “Mobile Applications” means applications downloaded by an authorized user of our hosted software applications to a mobile device.
- “Usage Data” means quantitative, anonymized, pseudonymized, or aggregated data derived from Users’ use of the Service. For the avoidance of doubt, Usage Data does not include Customer Data.
- “User” means an individual authorized by the Customer or Partner to access and use the Subscription Service.
- “Partner” means an entity that sells Punctuation products and services or provides services or technology to Punctuation customers that relate to the Service.
How We Obtain Information
We collect several types of information from and about our Customers, Users and Partners in the course of hosting, providing, maintaining, supporting and improving our Service. We process several types of information from the Service as a data processor for our Customers, including:
- Information and correspondence submitted to us in connection with our provision of the Service.
- Information we receive from our business partners in connection with provision or use of the Service or in connection with services provided by our business partners, including configuration of the Subscription Service.
- Server logs and any other ancillary data required to be processed in support of or in relation to the operation of the Service and the security of Customer Data.
We also process certain types of information from the Service as a data controller, including Account Data, Usage Data and certain User login data for certain Services.
How We Use Information
We may process personal data within the Customer Data to provide and support the Service. We do not use, disclose, review, share, distribute, transfer, or reference any Customer Data except as permitted in the Customer Agreement or as required by law.
In addition, we may use Account Data for billing, account management and contracting purposes. We process Usage Data for general maintenance, support, security, and improvement of the Service. We also process User login data to administer individual accounts related to training/learning activities.
Legal Basis
To the extent that we process Customer Data as a data processor, we do so in accordance with the Customer Agreement and the Customer’s instructions.
To the extent that we process Account Data or Usage Data or certain User login data as a data controller, we do so on the basis of our legitimate business interest to do so (taking into account the fundamental privacy rights of any relevant individuals), and/or on the basis of compliance with a legal obligation, and/or on the basis of consent, depending on the specific activity involved.
Where we have prior Customer agreement, we may process Customer Data as data controller for the purpose of training Punctuation’s artificial intelligence (“AI”) and machine learning (“ML”) models. Any processing is conducted on the basis of the legitimate interests of both Punctuation and our Customer, in order to improve these AI and ML models and, therefore, to provide a more accurate and reliable service to Punctuation’s Customers and Users. Where applicable, we also take steps to minimize the amount of personal data processed for this purpose. Users may exercise their right to object to this processing by contacting us. For further information on the exercise of your rights please see section “Your Privacy Rights” below.
How We Share Information Collected
We may disclose personal data comprised in Customer Data, Account Data or Usage Data to the following categories of recipients:
- To our subsidiaries and affiliates as necessary for the purposes outlined above.
- To our contractors, business partners and service providers we use to support our Service and business partners who provide services on behalf of our Customers.
- To a potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution or liquidation), in which case personal information held by us about our Customers and Partners will be among the assets transferred to the buyer or acquirer.
- To any competent law enforcement body, regulatory, government agency, court or other third party to: (i) comply with any court order, a request from any competent law enforcement agency, or any other legal obligation; (ii) enforce or apply the terms of the Customer Agreement; (iii) enforce or apply the terms of the agreement for partnership with our Partners; and (iv) protect the rights, property, or safety of Punctuation, our Customers, Users, or others.
- In accordance with Customer instructions.
International Transfers
We may store and process Customer Data, Account Data and Usage Data in: (i) any country where we have facilities, and (ii) any country in which we engage service providers. Any international transfer of Customer data will be carried out in accordance with the requirements in the applicable Customer Agreement.
For international transfers of personal data from the EEA, UK or Switzerland, we will implement such measures as are necessary to ensure we provide appropriate safeguards for the transferred data, including through the use of Standard Contractual Clauses or another lawful transfer data transfer mechanism.
Retention
We retain Customer Data according to the timeframes set forth in the Customer Agreement.
In circumstances where we are a data controller, we retain personal data only for so long as we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements, or to maintain a record of consent preferences).
Mobile Applications
We may obtain additional information through Mobile Applications that Customer or their Users download to their mobile device (“Device”). Mobile Applications we provide may obtain or collect information from a User’s Devices in connection with the User’s use of the Subscription Service, and are designed to interoperate with the Subscription Service; for instance, to provide a User with access to information within the Subscription Service or to provide information from a User’s Device to the Subscription Service.
General
Punctuation Applications for Third Party Services
We may also provide applications and integrations hosted by third party services (for example, messenger applications) for mutual customers that we have with such third‑party service providers. These applications and integrations will interact with the Subscription Service and our collection, use, and disclosure of information will be in accordance with this Services Notice and our Customer Agreement with the Customer. This Services Notice does not cover such third‑party service stores where we make our applications available. The use of any data you make available to such a third party is subject to that party’s privacy policy and your agreements with that party, if any.
Third Party Websites and Applications
Customers, Partners and other third parties, including our consultants, may develop applications (including Mobile Applications) or provide services to you or other third parties using our Service. This Services Notice does not apply to information collected by Customers, our business partners, and other third parties or third‑party applications (including Mobile Applications) or services, even if this information is collected using our Service.
Changes to this Services Notice
We reserve the right to update or change this Services Notice from time to time. For clarity, any update or change to this Services Notice will not change or modify the Customer Agreement.
Contact Information
To ask questions or comment about our information practices, contact us at: [email protected].
Or
ReCourses, Inc.
Attn: Privacy
4851 Vincion Rd
Murfreesboro, TN 37130
This website is operated by ReCourses, Inc. (the data controller), which is a Tennessee corporation located at 4851 Vincion Rd, Murfreesboro, TN, 37130.