Privacy Policy

At eshots (“eshots”, “us”, “we”, “our”), we understand your privacy is important and are committed to giving you control over your Personal Information (detailed below).

eshots helps brands improve their event marketing efforts with our advanced event marketing technology, services, and marketing science solutions. This Privacy Policy (the "Privacy Policy") explains how we collect, use, and disclose individuals’ information – including Personal Information – about you. We collect individuals’ information through several methods including: via www.eshots.com or any web site or mobile app owned and/or operated by eshots, eshots' epass platform, or eshots’ API services (a "Site"); for an event sponsored by one of our business customers (an "Event"); or received from any of our business customers in relation to the services that we provide to them (collectively, our “Services”). Please read this Privacy Policy carefully. Your use of the Site and your opt-in indicates to eshots that you have read, consent and agree to eshots' privacy practices, as outlined in this Privacy Policy, as updated from time to time.

Please note that this Privacy Policy does not govern practices of third parties, such as our business customers, other partners, third party service providers, or advertisers. Any information you provide to a third party while utilizing their website or service will be governed by the third party’s privacy policy and terms of use. Additionally, there may be circumstances in which the information we collect from you, including information you choose to give to us, may be subject to the privacy policies of our business customers, through which you reached us.

Information Collected

eshots may collect certain personal information about you in relation to the Services we provide.

Personal Information: “Personal Information” means data about a particular individual or household that directly or indirectly identifies, relates to, describes, could be reasonably linked with, or could be used to identify that person or household (or from those and other information either in our possession or likely to come into our possession). It may also include other information that may be associated with yourPersonal Information, such as Aggregate Information (defined below), if that information can be used to identify you, your household, or your device.We may collect the following “Personal Information” about you when you use our Services: your name, physical address, email address, and telephone number. We may also ask you to provide other types of information such as your gender, age or age range, birthdate, purchase history and horizon, products of interest to you, brand preference or perception, hobbies, marital status, level of education, salary or similar information. This information can be Personal Information to the extent that it could identify you, either directly or indirectly.

Personal Information Collected over the Last 12 Months: eshots has not collected any other types of Personal Information from our visitors and users over the last 12 months.

Aggregate Information (also known as “Website Usage Information”): In addition to the above, when you visit or download information from a Site, our web servers may automatically collect website usage information. Website usage information is non-Personal Information – that is, information that may not by itself identify a specific person – that describes how our visitors use and navigate a Site. It can include the number and frequency of visitors to each web page and the length of their stays, browser type, referrer data that identifies the web page visited prior and subsequent to visiting the Site, IP address (see below for more information on IP addresses), and location information (see “Use of Location-based Technology” for more information). We may determine the applicable technology available in order to serve you the most appropriate version of a web page, e-mail or similar service. In some situations, this Aggregate Information may be used or combined in a way that it identifies you. In those situations, such information will be treated like Personal Information.We may collect information about your use of our Site and other online services over time.

How We Collect Information

eshots collects and obtains your information in a few ways:  there is information that you choose to give to us, information we obtain through your use of our Site and other services, and information we obtain from third parties on behalf of our business customers.

Information You Give Us
If you choose to register and provide us with Personal Information, your Personal Information may be associated with your event participation.  We also collect information that you voluntarily provide through your use of the Site or other services – for instance, if you use our QuickCapture services (such as at a kiosk at an event or in a staff-assisted mode), or if you provide us with any photos or feedback.  

We also use “microsites” – that is, consumer-facing website products created by eshots that allow for data collection, viewing photos, videos, gaming scores, etc.  In order to use these microsites, you will be asked to provide certain Personal Information, such as your name, email address, and age.

Information We Gather When You Use Our Services
As noted above, we collect certain information from you through your use of our Services.  For instance, our web servers may automatically collect website usage information when you visit or download information from a Site.  

Information We Obtain from Other Sources / Third Parties
Finally, eshots may collect information from various third parties about you, such as any third-party providers who we use to provide certain services to you.  For instance, if you are using a pre-registration site for an event that uses our Services, your information may be transmitted to us through a third-party application program interface (“API”).  We may obtain your name, contact information, event you are trying to sign up for, items of interest, brand perception information, and other data.

Use of Cookies and Similar Technologies

Cookies are pieces of information that a web site either transfers to your computer's hard drive or stores temporarily in your computer's memory for record-keeping purposes. We may use cookies for a number of purposes, such as tracking usage patterns on a Site, facilitating the transmission of a communication, customizing your experience on a Site, facilitating your ability to navigate a Site, or as part of a verification or screening process. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent by indicating this in the preferences or options menu in your browser. You can also delete or remove cookies through your browser’s settings.  However, it is possible that some parts of a Site will not operate correctly if you disable cookies and you may not be able to take advantage of or participate in certain features of a Site. You should consult with your browser's provider/manufacturer if you have any questions regarding disabling or removing cookies.

A Site's pages or e-mail messages may contain a small graphic image called a web beacon (also known as a web bug or clear gif) that allows the party that set the web beacon to monitor and collect certain information about the viewer of the web page, web-based document or e-mail message, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. Web beacons can be very small and invisible to the user, but, in general, any electronic image viewed as part of a web page or e-mail, including HTML based content, can act as a web beacon. eshots does not have control over web beacons used by third parties and does not have access to what information, if any, they may collect.

Our third-party fulfillment providers, business customers, advertisers and other companies may use cookies or other similar technologies to collect your information and track your behavior.  These companies may collect information about your use of our Site or other services, and other online services over time and across different services.  Additionally, some companies may use information collected to deliver targeted ads on behalf of us or other companies, including on other websites or online services.  We are not responsible for the functioning of cookies or other technologies used and placed by third parties on your device.

Our Policy on “Do Not Track” Signals

We do not respond to “do not track” signals or similar mechanisms.  As we mentioned above, we may collect information about your use of our Site and other online services over time.

We cannot and do not control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

Use of Internet Protocol (IP) Addresses


An IP address is a number that's automatically assigned to your computer or network when you are on the Internet. When you request pages from a Site, eshots' servers log your IP address. eshots may use IP addresses for a number of purposes, such as system administration, to report aggregate information to our business customers or to audit the use of a Site. eshots may associate your IP address with other Personal Information you provide – in such cases, this information would be regarded as Personal Information.  eshots may also use IP addresses in cooperation with Internet service providers (“ISPs”) or to respond to appropriate and enforceable law enforcement requests, or if necessary to comply with relevant laws or legal obligations, or to protect a Site or its users.

Use of Location-based Technology

We may collect your precise, real-time location using GPS, cell phone towers, Wi-Fi signals, and/or other location-based technologies for purposes such as verifying your location and delivering or restricting relevant content based on your location.

We may also use beacon technology, including Apple's iBeacon. Beacons are electronic devices that broadcast signals that can be received by mobile devices on which one of our or our business customers' apps is installed. If you have voluntarily installed one of our or our business customers' apps on your device, and if you have granted permission for the app to track your location, then beacons installed at an Event may send a signal to the app on your device about the precise, real-time location of the device. The app may use this information to deliver updates and promotions to you, at a time and place when the information is most relevant. For example, if you are at an auto show Event, your mobile device may receive a signal from a beacon that causes the app to notify you about a specific automobile manufacturer's upcoming vehicle presentation. As a convenience to you, receipt of the beacon signals and delivery of the update or promotion may occur even if you are not currently using the app. To make our services operate better, we may also collect other information based on beacon signals, for example, the strength of the signal between the beacon and your device, the duration your device is near the beacon, or the battery level of the beacon itself.

How We Use Your Information

Business Purposes
eshots takes your privacy very seriously.  Your Personal Information is only used by eshots, its service providers, and the business customer whose Site or Event you visit. eshots may use your Personal Information only under the following circumstances:

- for purposes disclosed to you when you share your information on a Site or at an Event;
- to manage a Site or Event, including delivering updates and promotions regarding us and our business customers via beacon technology installed at an Event;
- to otherwise fulfill our operational purposes, such as operating our Sites, maintaining and improving our Services, detecting security incidents, and/or debugging our services;
- to contact you in connection with a sweepstakes, contest or other promotion in the context of the Event or Site which you visited;
- to contact you regarding any problems or questions we have relating to your use of a Site;
- to notify you of changes to our Privacy Policy or other policy or terms that affect you and your use of a Site, if we generally provide such notices to users;
- for purposes otherwise related to providing our Services to you, such as providing customer support, monitoring the usage of our services, and detecting and addressing technical issues.

You agree to provide eshots only with your own Personal Information, or the personal information of others you are authorized to provide.  eshots will only send communications to those who have requested information or otherwise agreed to or indicated a desire to hear from us.

Please note that information submitted to a Site via a "contact us," "help" or other similar e-mail address or form will not necessarily receive a response. We will use the information provided to these e-mail addresses or forms only to respond, if at all, to any question or comment submitted. We will not use the information provided to these e-mail addresses or forms for marketing purposes unrelated to your request..

Disclosing/Sharing Personal Information

eshots does not sell, rent, or lease your Personal Information. Personal Information collected by eshots when you visit a Site will only be shared with the business customer whose Site you visit and to which you disclose your information, and for the other business purposes outlined below. Your Personal Information is only used as disclosed on a Site or registration form and is not shared with other parties, except for the limited circumstances stated below:

· When you affirmatively agree to the disclosure. For example, if you agree to take a survey with a business customer or request to receive additional information from a business customer through a Site or at an Event, we may share your information, including your personal information, with that business customer;

· If you scan or use your Event pass at a business customer's booth at an Event (such as at an on-site kiosk), we may share the information associated with your Event pass, including Personal Information, with that business customer;

· If you opt-in to location-based services through your device settings, we may share information collected through location-based services, including through beacon technology, with our business customers;

· To fulfill orders for products or services that you place with eshots or a Site;

· To fulfill legal requirements for a sweepstakes, contest or promotion, including, without limitation, disclosure on a winners’ list and in connection with prize fulfillment. By entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor of the promotion to use your name, voice or likeness in advertising or marketing associated with the promotion or otherwise;

· To investigate, protect against and help prosecute individuals responsible for malicious, deceptive, fraudulent, or illegal activity involving or affecting eshots, our Services, our users, and/or our customers.

· In response to a lawful and enforceable request from local, state or federal law enforcement officials or other governmental authorities conducting an investigation; by any lawful judicial, administrative, or similar proceeding or order (such as a subpoena); or otherwise where eshots has a good faith belief that such disclosure is necessary to protect the legal rights of a Site, our users, or others;

· To verify or enforce your compliance with eshots' policies;

· In the event eshots merges with or acquires another business entity, or its assets related to the products or services that you receive from eshots are acquired by another business entity, or its business is consolidated, or it goes through a fundamental corporate change; and

· When eshots employs third parties to perform functions on its behalf. These include, without limitation, third party hosting companies, communication services (including e-mail and mail), data analysts, promotion agencies, classified fulfillment and processing companies, credit card transaction processors, companies that provide user and marketing assistance, companies that create, host, fulfill or run contests/sweepstakes/games and other customer service companies.

Please note that if you agree to receive communications from a third party (including our business customers), your information will be subject to the third party's privacy policy. Therefore, you will need to contact the third party directly if you have any questions on how they use your information.

eshots may also disclose non-personally identifying information, such as aggregated user statistics, to third parties for several reasons, including, without limitation, describing eshots and a Site to third parties, or improving the performance of a Site or other services.

Categories of Third Parties that Receive Personal Information

We share or otherwise disclose individuals’ Personal Information to the following categories of third parties:

Business Customers:  we share your Personal Information with those eshots business customers that you seek information from or agree to provide your information to – such as when you complete a business customer’s survey or use your Event pass at a business customer's booth at an Event.

Fulfillment Partners:  We employ third party providers, companies, individuals, and agents to facilitate and help us provide our Services and other services related to your coverage to you.  Such fulfillment partners perform tasks or functions on our behalf, provide Service-related services, or assist us in analyzing how our Services are used or delivered.  As mentioned above, these include, without limitation, third party hosting companies, communication services (including e-mail and mail), data analysts, promotion agencies, classified fulfillment and processing companies, credit card transaction processors, companies that provide user and marketing assistance, companies that create, host, fulfill or run contests/sweepstakes/games and other customer service companies.

These third parties are granted access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Other eshots Entities:  We may share or disclose your information to other entities in the eshots family.

Categories of Personal Information Disclosed for Business Purposes


We may share the types of Personal Information as defined in this Privacy Policy related to the above-outlined business purposes.

Categories of Personal Information Sold

eshots does not sell, rent or trade its customers' personal information to third parties.

Please note that a “sale” of Personal Information does not include those instances when such information is part of a merger, acquisition, or other transaction involving all or part of our business.  If we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a merger or other business transaction, we may transfer your Personal Information to a third party as part of that transaction.  If such transaction materially affects the manner in which your Personal Information is processed, we will notify you of such change prior to its implementation.

Retention

eshots may retain your information for two (2) years, unless we receive a request from you to delete your information sooner. 

Requests for changes in use

In connection with the processing of your Personal Information, you may also request that we change how we use the personal data you have provided. This includes the right to withdraw consent or permission for us to keep your personal data, and right to change how we use or share the information we have collected about you. To make changes to how we use your information, please contact us.  See the “Contact Us” section below.

Links

While on a Site or viewing an e-mail or other content provided by eshots or a Site, you may encounter links to other websites or online materials operated by third parties (including our business customers). If you "click" on a link to such a third party, the "click" takes you off the Site and to a third party's website, which is beyond eshots' control. Moreover, the data collection and use practices by these third parties are governed by their own privacy policies and practices, and not eshots’ Privacy Policy.  For instance, these other websites may set their own cookies (there is information above about cookies), collect data or have other privacy practices. We encourage you to review the privacy policy of any other website you visit. Links to any third party website or content do not constitute or imply an endorsement or recommendation by eshots of the linked website or content.

Security

eshots stores the information we collect from you on limited access servers, and eshots takes steps to maintain the security of eshots' servers and to protect your personal information from unauthorized disclosure. However, no data transmission over the Internet or electronic storage of information can be guaranteed to be 100% secure. eshots cannot ensure or warrant the security of any information you transmit to eshots and you do so at your own risk.

Consent to Transfer

This Site is operated in the United States. If you are located outside of the United States, please be aware that any information you provide to eshots will be transferred to the United States. Please also be aware that U.S. data protection laws are not deemed to be as adequate as those in other jurisdictions like the European Union.   Additionally, eshots may transfer your information to partners in third countries.  By using this Site, participating in any of eshots' services or providing eshots with your information, you consent to such transfers..

Your California Privacy Rights

California residents are afforded certain rights related to their information under state law.  eshots aims to take reasonable steps to allow California residents to access, delete or know about the use of your Personal Information, and exercise other rights available under applicable law.  eshots informs you that, where applicable under relevant law, individuals may be entitled to the following:

Right to Access / Disclosure:
to have access to your Personal Information upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the collection or processing.

Disclosure of Direct Marketers:  to have access upon simple request, and free of charge, the categories and names of addresses of third parties that have received Personal Information for direct marketing purposes.  Please see the “Direct Marketers Disclosure” section below for more information.

Collecting, Selling, Sharing, or Disclosing Personal Information:  upon receipt of a verifiable request, to obtain a list of:

- The specific pieces of your Personal Information eshots holds;
- The categories of Personal Information collected about you, sold to third parties, or disclosed to third parties for business purposes;
- The categories of Personal Information sold within the last 12 months;
- The categories of sources from which Personal Information is collected;
- The business or commercial purpose for collecting or selling Personal Information; and
- The categories of third parties with whom Personal Information is shared, sold, or disclosed for a business purpose.

Right to Opt-Out of the Sale of Personal Information:  California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt-out of the sale of their Personal Information under certain circumstances.  As noted elsewhere, however, eshots does not sell individuals’ Personal Information.

Right to Deletion / “Right to be Forgotten”:  to obtain the deletion of your Personal Information in the situations set forth by applicable data protection law and upon receipt of a verifiable request.

Right to Data Portability:  to have your Personal Information directly transferred by us to a third-party processor of your choice (where technically feasible; may be limited to situations when processing is based on your consent).

Right to Non-Discrimination.  As defined under relevant law, you have a right to non-discrimination in the Services or quality of Services you receive from us for exercising your rights.Please contact us at the information in “Contact Us” Section below in relation to exercising these rights.  Note that we may ask you to verify your identity before responding to such requests.

Direct Marketing Disclosures

California Civil Code section 1798.83 allows customers who are California residents to ask us for a notice describing what categories of personal information we share with third parties or corporate affiliates for their direct marketing purposes.  If you are a California resident, you have the right to request the following information:

1.) the categories of information we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year;
2.) the names and addresses of the third parties that received the information; and
3.) if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

To make such a request, please provide sufficient information for us to determine if this applies to you, and attest to the fact that you are a California resident.  Please also provide a current California address for our response. You may make this request in writing to us at the below address.  Any such request must include “California Privacy Rights Request” in the first line of the description, and include your name, street address, city, state and ZIP code.  Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the address provided for this purpose below.Note that responsive information may be provided in a standardized format that is not specific to you.

Children Under 13 Years of Age

The Site is not directed to or intended for children under the age of 13, and eshots does not knowingly collect personal information on a Site from children under 13 years of age. If eshots discovers that a child under the age of 13 has provided eshots with Personal Information through a Site, eshots will delete that child's personal information from its system.

Acceptance & Privacy Policy Changes

By using this Site and opting in, you acknowledge that you have read, accept, and consent to our privacy practices, as outlined in this Privacy Policy and our Terms and Conditions.

eshots reserves the right to modify, alter or otherwise update this Privacy Policy at any time and in our sole discretion. We will post any new or revised policies on the Site and include the new Privacy Policy’s modification date, noting when the new policy is effective. Please note, however, that we will apply only the Privacy Policy in effect at the time you submit your Personal Information to a Site, unless you affirmatively consent to any new or revised Privacy Policy.

Submitting a Verifiable Request to eshots

As mentioned above, California residents have certain rights to access, delete, or otherwise control the use, collection, and/or disclosure of their information. We will respond to an individual’s “verifiable request” to exercise his or her rights under such laws – that is, where eshots has received a request purporting to be from a particular individual, and eshots has been able to verify the individual’s identity. The need to verify an individual’s identity is critical to protecting your information, and ensuring that your information is not shared with anyone pretending to be you or someone who is not authorized to act as your agent on your behalf.

You may submit a verifiable request via our email address, mailing address, or toll-free number, listed in the “Contact Us” section below, or as otherwise provided on our Website (if such means are available). eshots will ask you to provide information about yourself so that we can verify your identity as part of this process. This information may include your name, your address, your account information, and any other information deemed necessary by eshots to reasonably verify your identity, to ensure that your information is not shared with anyone impersonating you.

We may ask for additional information if we have difficulty confirming your identity. We will not share your information or honor other requests in those situations in which we are unable to confirm a request for your information is a “verifiable request.”

Under California law a consumer can appoint an “authorized agent” to make certain verifiable requests upon their behalf, such as the right to know what information we collect about the consumer or to request deletion of the consumer’s information. Because the security and privacy of your information is paramount, we will ask that you identify and provide permission in writing for such persons to act as your authorized agent and exercise your applicable rights under California law in such situations. This may require us to contact you directly and alert you that an individual has claimed to be your agent and is attempting to access or delete your information. We will also independently verify your identity to ensure that an unauthorized person is not attempting to impersonate you and exercise your rights without authorization. We will not share your information or honor any other requests in those situations where you cannot or do not grant permission in writing for an identified authorized agent to act on your behalf, or where we cannot independently verify your identity.

Contact Us

If you have any questions, comments or concerns about this Privacy Policy, please contact us at customer_support@eshots.com or by calling us toll-free at 844-550-2035 and asking for the Privacy Department or mailing a letter to 200 E. Randolph Street, Suite 5215, Chicago, IL 60601 USA, ATTN: Privacy Department.

EU Privacy Rights

Individuals in the EU may have additional rights under relevant law, including:

· Right to Access / Disclosure: to have access to your Personal Information upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the processing.
· Right to Correction: for EU data subjects, to correct your Personal Information if you find it is inaccurate, incomplete or obsolete.
· Right to Deletion / “Right to be Forgotten”: to obtain the deletion of your Personal Information in the situations set forth by applicable data protection law.
· Withdraw of Consent to Processing: for EU data subjects, to withdraw your consent to the data processing without affecting the lawfulness of processing, where your Personal Information has been collected and processed based on your consent and not any other basis.
· Right to Object: for EU data subjects, to object to the processing of your Personal Information under certain circumstances, in which case we may ask you to justify your request by explaining to us your particular situation.
· Right to Restrict Processing: for EU data subjects, to request limits to the processing of your data, when allowed by and in circumstances set forth under applicable law.
· Right to Data Portability: to have your Personal Information directly transferred by us to a third-party processor of your choice (where technically feasible; may be limited to situations when processing is based on your consent).

EU data subjects also have the right to complain to a Data Protection Authority (“DPA”) about our collection and use of your Personal Information. For more information, please contact your DPA. EU data subjects also have the right to object to automated decision-making that produces a legal effect on the data subject.

Difficulty Accessing Our Privacy Policy?

Individuals with disabilities who are unable to usefully access our privacy policy online may contact us at the above-listed contact information to inquire how they can obtain a copy of our policy in another, more easily readable format.

Effective Date

This eshots Privacy Policy has an effective date of 12.26.2019.