WillowTree Privacy Policy.

This Privacy Policy describes how Willow Tree, LLC and our affiliates (“Willow Tree,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information.  This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.  You can jump to particular topics by going to the headings below.  Note that Willow Tree develops apps for other companies.  This Privacy Policy does not relate to any information that is collected by an App developed by Willow Tree for a third party.

How We Collect Information

We collect information about you in a variety of ways depending on how you interact with us and our websites and services, including:

  • Directly from you when you provide it to us, such as when you sign up to receive newsletters, updates, or other information from us or contact us by phone, e-mail, or otherwise.
  • Automatically when you interact with our websites or emails through the use of cookies, server logs, and other similar technologies.
  • From other sources, including, for example, third parties, business partners, our affiliates, or publicly available sources.  For example, if you submit a job application, or become an employee, we may conduct a background check.

For a list of the categories of personal information that we collect see the chart below in the Sharing of Information Section.

Use and Processing of Information

The following provides examples of how we use the information that we collect.

Client Information

Types of Data: We collect the name, and contact information, of our clients and their employees with whom we may interact.

Primary Purpose for Collection and Use of Data: We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.

Cookies and First Party Tracking

Types of Data: We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed.

Primary Purpose for Collection and Use of Data: We have a legitimate interest in making our website operate efficiently.

Cookies and Third Party Tracking

Types of Data: We may place tracking technology on our website that collects analytics or allows us to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can report analytics to us or provide advertising about products and services tailored to your interests on our website, or on other websites.

Primary Purpose for Collection and Use of Data: Where required by law, we base the use of third party cookies upon consent.

Demographic Information

Types of Data: We collect personal information, such as the age or location of individuals that apply for a job with us.

Primary Purpose for Collection and Use of Data: We have a legitimate interest in understanding our job applicants and employees and meeting our employment related legal obligations.

Employment

Types of Data: If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee.  This may include, among other things, your Social Security Number.  Providing this information is required for employment.

Primary Purpose for Collection and Use of Data: We use information about current employees to perform our obligations to employees.  In some contexts, we are also required by law to collect information about employees or applicants.  We also have a legitimate interest in using your information to have efficient staffing and work force operations.

Employee Directory

Types of Data: When you become an employee we will collect information necessary to ensure that other employees can contact your or find out more about your team and job. Information we collect and use in this context may include, among other things, your work email address, your office location, your job title, and department.

Primary Purpose for Collection and Use of Data: We use this information about current employees to provide our employees with information and resources they need to fulfill their obligations.  We have a legitimate interest in ensuring that our employees are able to locate and contact one another in order to complete tasks and learn about available resources.

Feedback/Support

Types of Data: If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.

Primary Purpose for Collection and Use of Data: We have a legitimate interest in receiving, and acting upon, your feedback or issues.

Body position

Types of Data: Our Vocable App collects information about your body position in order to allow you to navigate on-screen controls or otherwise interact with the services by monitoring your face and head movements.

Primary Purpose for Collection and Use of Data: We use your body position information only if you have provided us consent to access your camera for this purpose. We also have a legitimate interest in allowing our users to interact with our services using solely their head and face positioning.

Mobile Devices

Types of Data: We collect information from your mobile device such as unique identifying information broadcast from your device when using Willow Tree controlled Apps or visiting our websites.

Primary Purpose for Collection and Use of Data: We have a legitimate interest in identifying unique visitors, and in understanding how users interact with our products and services on their mobile devices.

Newsletter List

Types of Data: When you sign up for one of our newsletters we collect your email address.

Primary Purpose for Collection and Use of Data: We share information about our products and services with individuals that consent to receive such information.  We also have a legitimate interest in sharing information about our products or services.

Public Health and Safety

Types of Data: In certain situations where a serious public health threat has been identified, we may collect information from employees, guests, and other individuals accessing our facilities. This may include medical and health information, such as body temperature, symptoms, and underlying health conditions. In some cases, we may also collect medical, health, and related information about an employee’s children, family member, or other individuals under the employee’s care.

Primary Purpose for Collection and Use of Data: We have a legitimate interest in protecting the health and safety of our employees and guests. In some jurisdictions we may be required by law, regulation, or governmental order to collect and retain information related to issues of public health and safety. We have a legitimate interest in complying with the laws in the jurisdictions in which we operate.

Speech Recognition

Types of Data: Our Vocable App may collect audio in order to allow you to convert speech into text and otherwise interact with the services.

Primary Purpose for Collection and Use of Data: We use audio  information with your consent. We also have a legitimate interest in enabling our users to interact with our services using voice only.

Surveys

Types of Data: When you participate in a survey we collect information that you provide through the survey.  If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.

Primary Purpose for Collection and Use of Data: We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization.

Website interactions

Types of Data: We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms.  This may also include information about your device or browser.

Primary Purpose for Collection and Use of Data: We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful.  We also have a legitimate interest in detecting and preventing fraud.

Web logs

Types of Data: We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

Primary Purpose for Collection and Use of Data: We have a legitimate interest in monitoring our networks and the visitors to our websites.  Among other things, it helps us understand which of our services is the most popular.

In some countries, such as Canada, our legitimate interest in processing your data arises when we obtain your express or implied consent. Where Canadian law applies to our collection of personal information, by continuing to use our site and services you are acknowledging and consenting to the collection and use of information as described herein.

In addition to the purposes and uses described above, we use information in the following ways:

  • To identify you when you visit our websites or our stores.
  • To provide products and services.
  • To improve our services and product offerings.
  • To conduct analytics.
  • To respond to inquiries related to support, employment opportunities, or other requests.
  • To send marketing and promotional materials including information relating to our products, services, sales, or promotions, or those of our business partners.
  • For internal administrative purposes, as well as to manage our relationships.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.  For example, if you engage us to build a mobile app for you we may collect your information to perform our contract with you (or your company), but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your engagement.  As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Sharing of Information

In addition to the specific situations discussed elsewhere in this policy, we may disclose personal information in the following situations:

  • Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).  If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
  • Other Disclosures with Your Consent.  We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
  • Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws.  We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the  provision of services by a third party intermediary.
  • Service Providers. We may share your information with service providers.  Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.

Some jurisdictions require us to disclose whether the following categories of personal information are collected, disclosed to third parties for a “business purpose,” or “sold” or transferred for “valuable consideration.” The table below indicates the categories of personal information we collect and transfer in a variety of contexts.  Note that we do not “sell” personal information.

Categories of Personal Information We Collect

Identifiers

This may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.

To Whom We Disclose Personal Information for a Business Purpose

  • Affiliates or subsidiaries
  • Data analytics providers
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Internet service providers
  • Joint marketing partners
  • Other Service Providers
  • Payment processors and financial institutions
  • Professional services organizations, this may include auditors and law firms

To Whom We Share Personal Information for Targeted Advertising

  • Advertising networks

Government Issued Identification

This may include information collected in an employment context such as social security number, driver’s license number, or state issued identification number, passport number.

To Whom We Disclose Personal Information for a Business Purpose

  • Affiliates or subsidiaries
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

Financial Information

This may include bank account number, credit card number, debit card number, and other financial information.

To Whom We Disclose Personal Information for a Business Purpose

  • Affiliates or subsidiaries
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Payment processors and financial institutions
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

To Whom We Share Personal Information for Targeted Advertising

  • N/A

Health Related Information

This may include information collected in the employment context such as medical information, mental or physical condition or treatment, or health insurance information

To Whom We Disclose Personal Information for a Business Purpose

  • Affiliates or subsidiaries
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

To Whom We Share Personal Information for Targeted Advertising

  • N/A

Characteristics of Protected Classifications

This may information collected in the employment context such as include age, sex, race, ethnicity, physical or mental handicap, etc.

To Whom We Disclose Personal Information for a Business Purpose

  • Affiliates or subsidiaries
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

To Whom We Share Personal Information for Targeted Advertising

  • N/A

Internet or Other Electronic Network Activity Information

This may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.

To Whom We Disclose Personal Information for a Business Purpose

  • Affiliates or subsidiaries
  • Data analytics providers
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Internet service providers
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

To Whom We Share Personal Information for Targeted Advertising

  • Advertising Networks

Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information

To Whom We Disclose Personal Information for a Business Purpose

  • Affiliates or subsidiaries
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

To Whom We Share Personal Information for Targeted Advertising

  • N/A

Professional or Employment-Related Information

To Whom We Disclose Personal Information for a Business Purpose

  • Affiliates or subsidiaries
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

To Whom We Share Personal Information for Targeted Advertising

  • N/A

Inferences Drawn From any of the Information Listed Above

To Whom We Disclose Personal Information for a Business Purpose

  • Affiliates or subsidiaries
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

To Whom We Share Personal Information for Targeted Advertising

  • N/A

Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

This may include signature, physical characteristics or description, insurance policy number.

To Whom We Disclose Personal Information for a Business Purpose

  • Affiliates or subsidiaries
  • Government entities, as may be needed to comply with law or prevent illegal activity
  • Other service providers
  • Professional services organizations, this may include auditors and law firms

To Whom We Share Personal Information for Targeted Advertising

  • N/A

Some jurisdictions also require that we provide our purpose for collecting the following types of personal information:

Categories of Sensitive Personal Information We Collect

Health related information

Purposes for which it is collected

  • To perform our legal obligations to our employees.

Social security, driver’s license, state identification card, or passport number.

Purposes for which it is collected

  • Required by law from employees
  • Eligibility for employment
  • Business travel

Racial or ethnic origin, religious or philosophical beliefs, or union membership.

Purposes for which it is collected

  • To comply with our employment related legal obligations.
  • To create and promote a diverse and inclusive workforce.

Your Choices

Some jurisdictions give you a right to make the following choices regarding your personal information:

  • Access To Your Personal Information. You may request access to your personal information or confirmation that we have information about you, including in some circumstances information about the entities to whom we have shared personal information by contacting us at the address described below. If required by law, upon request, we will grant you access to the personal information that we have about you. In some circumstances, upon your request, we may provide you with a copy of the personal information we have about you in a portable, machine-readable format.
  • Changes To Your Personal Information. If our website does not permit you to update or correct certain information, you can contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
  • Deletion of Your Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law.  You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below.  If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.
  • Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
  • Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
  • Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties.  You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  If you decide not to receive promotional emails, we may still send you service related communications.
  • Revocation of Consent.  If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

You may exercise the rights described above through by contacting us as indicated in the “Contact Information” section below.  We do not discriminate against individuals that exercise rights conferred by law.

Note that, as required by law, we will require you to prove your identity.  We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, email address, and in some cases we may ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of a completed Authorized Agent Designation Form indicating that you are able to act on another person’s  behalf.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our services permit you to create an account.  When you do you will be prompted to create a password.  You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you.  You should notify us of any unauthorized use of your password or account.

Other Important Information

The following additional information relates to our privacy practices:

  • Transmission of Information To Other Countries. As a multi-national company we transmit information between and among our affiliates.  As a result your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country.  Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below. For data that we collect in Europe and transmit outside of the European Economic Area to countries that are not considered by the European Commission to have similar data privacy laws, we utilize the European Commission approved Standard Contractual Clauses.  You may also request a copy of any Standard Contractual Clauses we use by contacting us using the contact information below.
  • Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.  This includes websites or applications that we developed for third parties.
  • Changes To This Privacy Policy. We may change our privacy policy and practices over time.  To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy.  Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
  • Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below.  We will attempt to respond to your requests and to provide you with additional privacy-related information.

info@willowtreeapps.com
Willow Tree, LLC
1835 Broadway St
Charlottesville, VA 22902
888-329-9875

If you are not satisfied with our response, and are in the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority.

This Privacy Policy was last revised on, and effective as of August  2022.