Effective as of Aug 1, 2021
We at White Cup (White Cup, Inc., and our parent company, Eden Capital Management, LLC) are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by White Cup as a controller, including the information collected on our websites (help.whitecupsolutions.com, learning.whitecupsolutions.com, ideas.whitecupsolutions.com, go.whitecupsolutions.com) or through other channels such as (HubSpot, Zendesk, Skilljar, Cvent, Wistia). This Privacy Notice describes how we collect, receive, use, store, share, transfer, and process your personal information. It also describes your choices regarding use, as well as your rights of access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the Website.
We periodically update this Privacy Policy. We will post any privacy policy changes on this page.
While we will notify you of any material changes to this Privacy Policy prior to the changes becoming effective, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy archived for your review.
If you have any questions about this Privacy Policy or our treatment of the information you provide us, please contact us by email at info@whitecupsolutions.com or by mail at 7154 W State Street #404 Garden City, ID 83714 Attn: Privacy.
Our Use of the Subscription Form
We use our own subscription form to build interest around developing content, webpages, industry educational material, and other leadership information that people can visit to learn more about White Cup. Information that we collect and manage using the subscription form on our website is for our own marketing belongings to use, and is used, disclosed, and protected according to this Privacy Policy.
When You Visit our Websites
You are free to explore the websites without providing any Personal Information about yourself. When you visit the websites or register for the newsletter subscription, submit a form for content, or register for an event, we request that you provide Personal Information about yourself, and we collect Navigational Information.
“Personal Information”
We collect personal information from you when you submit web forms or interact with our website, for example, subscribing to a newsletter, signing up for a webinar, or requesting customer support.
“Personal Information” refers to any information that identifies you personally, including contact information, such as your name, email address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter on our websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter, and Google, or information that we acquire from service providers.
Personal Information includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual.
Navigational information refers to information about your computer and your visits to the websites such as your IP address, geographical location, browser type, referral source, length of visit, and pages viewed. Please see the “Use of Navigation Information” section below.
Payment information includes information we collect and process from you when you register for an event, including credit card numbers and billing information, using third-party PCI-compliant service providers. Except for this, we do not collect other Sensitive Information from you.
“Sensitive Information”
This refers to credit or debit card numbers, financial account numbers or wire instructions, government-issued identification numbers (such as Social Security numbers, passport numbers), biometric information, personal health information (or other information protected under any applicable health data protection laws), and personal information of children protected under any child data protection laws.
Log Files
When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times, and referring website addresses. This information is used by White Cup to provide general statistics regarding the use of our websites. For these purposes, we do link this automatically-collected data to other Personal Information such as name, email address, address, and phone number.
Information we collect from third parties
From time to time, we may receive Personal Information about you from third-party sources, including partners with which we offer co-branded services or engage in joint marketing activities, and sources such as social media websites.
Information About Children
The White Cup websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect personal information about children under 16. If you believe that we have collected personal information about a child under 16, please contact us, so that we may delete the information.
Compliance with Our Privacy Policy
We use the information we collect only in compliance with this Privacy Policy. Customers who subscribe to our content are obligated through our agreements with them to comply with this Privacy Policy.
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:
improve your browsing experience by personalizing the Websites;
develop and improve our products and services;
send information or White Cup content to you that we think may be of interest to you by post, email, or other means, and send you marketing communications relating to our business;
promote the use of our services to you and share promotional and information content with you in accordance with your communication preferences;
provide other companies with statistical information about our users — but this information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis;
contact you about billing, account management, and other administrative matters;
send information to you regarding changes to our Customer Terms of Service, Privacy Policy (including the Cookie Policy), or other legal agreements;
investigate and help prevent security issues and abuse; or
meet legal requirements.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to a third party.
Legal basis for processing Personal Information (EEA visitors only)
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the websites and to provide you with a better experience when you interact with White Cup. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about White Cup. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.
You may disable the collection and use of your location data through browser-, operating system- or device-level settings. Consent concerning location data may be withdrawn at any time.
Customer Testimonials and Comments
We post customer testimonials and comments on our websites, which may contain Personal Information. We obtain each customer’s consent prior to posting the customer’s name and testimonial.
Use of Payment Information
If you give us Payment information, we use it solely as authorized by you in accordance with this Privacy Policy for you to use the registration process, including to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. All Personal Information is protected using appropriate physical, technical, and organizational measures.
Social Media Features
Our websites include Social Media Features, such as the Facebook Like button and Widgets, such as the Share Button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
External Websites
Our websites provide links to other websites of third parties. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.
Public Forums
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in “To Unsubscribe From Our Communications” below.
Retention of Personal Information
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements). If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
Service Providers
We employ other third-party service providers to provide services on our behalf to visitors to our websites and our customers. We do not share your phone number data or consent regarding phone number usage with third-parties/affiliates or partners. We may need to share your information with them to provide information, products, or services to you. We might also share data with third parties but only if the data has been de-identified in a way so it cannot be used to identify you. Examples may include removing repetitive information from prospect lists, analyzing data, or performing statistical analysis or interactions on our websites, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and data protection policies and standards.
White Cup Partners
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
We partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you. When you engage with these co-marketing partners, we will tell you who we are sharing data with and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt out of the partner’s communications. These co-marketing partners are required to adhere to our privacy and data protection policies.
Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by White Cup on the websites and product services. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
Cookies
White Cup and our partners use cookies or similar technologies (such as web beacons and JavaScript) to analyze trends, administer the website, track users’ movements around the website, and gather demographic information about our user base.
Third-Party Tracking Technologies
Our websites use technologies of third-party partners [such as HubSpot, Zendesk, Skilljar, Cvent, Wistia] to help us recognize your device and understand how you use our websites so that we can improve our services to reflect your interests and serve you advertisements about our products and services that are likely to be of more interest to you. Specifically, [HubSpot, Zendesk, Skilljar, Cvent, Wistia], our third-party partners, collect information about your activity on our website to enable us to:
Measure and analyze traffic and browsing activity on our websites.
Show advertisements for our products and/or services to you on third-party sites.
This Service Privacy Notice also identifies what rights you have concerning the collection of this data, such as the right to opt out of interest-based advertising (also commonly referred to as targeted or personalized advertising).
Advertising
We partner with third-party ad networks to either display advertising on our website or to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect information about your activities on this and other websites to provide you with targeted advertising based on your interests. If you wish not to have this information used for the purpose of serving you targeted ads, you may opt out by clicking here:
http://optout.aboutads.info/ or http://optout.networkadvertising.org/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
Cross-Device
Your personal information is being used for White Cup marketing purposes. Our advertising Partners perform a hash of your email address in order to serve targeted advertising to other devices connected to you (via cross-device tracking). By submitting a form, you acknowledge hashing and cross-device activity.
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
You can request access, correction, updates, or deletion of your personal information.
You can object to the processing of your personal information, ask us to restrict processing of your personal information, or request portability of your personal information.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information.
To exercise any of these rights, please contact us by email at info@whitecupsolutions.com or by mail at 801 Second Avenue, Suite 600, Seattle, WA 98104 Attn: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
To Unsubscribe from Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located at the bottom of our e-mails, updating your communication preferences, or by contacting us by email at info@whitecupsolutions.com or by mail at 801 Second Avenue, Suite 600, Seattle, WA 98104 Attn: Privacy. Customers cannot opt-out of receiving transactional emails related to their accounts.
This section applies only to California consumers. It describes how we collect, use, and share California consumers’ Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell Personal Data. White Cup is a business and does not sell Personal Data. We may share Personal Data with third parties if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Data.
If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.
For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act (“CCPA”).
How We Collect, Use, and Share your Personal Information
We have collected the following statutory categories of Personal Information in the past twelve (12) months:
Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or from third-party sources.
Commercial information, such as subscription records. We collect this information directly from you.
Internet or network information, such as browsing and search history. We collect this information directly from your device.
Geolocation data, such as IP address. We collect this information from your device.
Financial information, such as Payment Information or financial account numbers in the process of providing you with a subscription. We collect this information from you.
Inferences.
Other personal information, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing a registration or subscription form.
Your California Rights
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
The right of access means that you have the right to request that we disclose what Personal Information we have collected, used, and disclosed about you in the past 12 months.
The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
How to Exercise your California Rights
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your Personal Information.