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Canvas Privacy Policy

Effective February 7, 2019

Introduction

Centercode, Inc. (“Centercode”) owns and operates the software as a service platform commonly known as the “Centercode Platform.” The Centercode Platform is provided by Centercode to its customers as a service. The Canvas site (www.citicanvas.centercode.com) (the “Canvas”) is a web-based test participation portal built on the Centercode Platform for a Centercode customer, Citibank, N.A. or its affiliates (our “Customer”), to collect, organize, and announce opportunities to participate in alpha, beta, and field tests of our Customer’s products and services (collectively “Customer Validation” tests) and to conduct these Customer Validation Tests.

Given the nature of Canvas, we collect and manage a significant amount of personal information about community members. As such, data privacy is always top of mind with regards to how we design both our platform and our service offerings. Our continuous goal is to handle all data as respectfully and responsibly as possible, while being completely transparent as to what exactly that means.

We also understand that privacy is a complex subject, and focusing strictly on the legal details doesn't necessarily highlight the items that are most important to many in our audience. Given that context, we've deliberately split our policy into two parts. The first section is intended to provide a plain-English overview of the topics that we feel are most interesting to the majority of our users. The next section provides the comprehensive details that the truly savvy are more likely to care deeply about.

Regardless, we comply with and are passionate about this entire policy, and would encourage you to take your time in reviewing this entire policy. Also, please don't ever hesitate to reach out to us at privacy@centercode.com if you have any feedback or questions. If you don't agree with any aspect of this policy, you should not use our services or sites, including Canvas.

Key Terms

  • Canvas is an online portal that allows individuals to apply for and test new products and services on behalf of our Customer. Canvas is provided by us, Centercode, on behalf of our Customer to help our Customer execute its Customer Validation tests. By joining Canvas, you're expressing an interest in participating in these types of opportunities. In addition to managing Canvas, Centercode designs and develops the software platform which Canvas is built on, the Centercode Platform, which is also used by many other companies.
  • Your Canvas Profile is comprised of data that you directly provide to Canvas. This includes Personal Profile data, such as account (e.g. name, email) and demographic information (e.g. gender, age), and test platform data, which describes things you own or have access to (e.g. your phone, house, or computer) that may interact with the products you’re testing. This information is used to offer ideal testing opportunities based on your interests, and to contextualize the feedback you provide in any tests we manage for our Customer through Canvas that you choose to participate in. For example, if our Customer wanted to know which features were in most demand by people in a certain age range, this allows them to find the answer without asking your age every time you suggest a feature. We don't sell this information, and we only grant access to this information to our Customer.
  • Test Feedback includes everything you provide when applying for, and participating in a specific test within Canvas. This typically takes the form of things like bug reports, feature suggestions, file uploads, and survey responses. This is the information our Customer needs to improve its products. By providing this information, it's important that you understand that our Customer will own this data. As such, you should only create a Canvas account and apply for tests if you're comfortable with providing both your Canvas Profile information and your specific Test Feedback to our Customer.

Key Concepts

  1. Canvas Profile information provided to Canvas is used to identify appropriate candidates for product tests through Canvas. From time to time we may also use it for aggregate research purposes. We don't sell or share this information for purposes other than these tests. Beyond your basic member profile, you can choose how much information you provide, understanding that providing more information increases the opportunities available to you, as we can better target you for those opportunities.
  2. If you receive an announcement for a Canvas testing opportunity that you find interesting, and you choose to pursue that opportunity (which requires logging in to Canvas and completing an application), your personal information may then be shared with our Customer. This is to ensure that you're an ideal candidate for that test.
  3. If you're selected for a Canvas test, and actively choose to join it (which typically involves completing both participation and non-disclosure agreements), your Canvas Profile will continue to be available to our Customer, as well as any feedback or files that you provide throughout the test. Again, please understand that our Customer owns this information and feedback.
  4. While participating in a Canvas test, other testers will have access to some personal data about you, as we see fit, based on the needs of that test. This will typically include your full real name and much of your feedback. Note that our tests are typically run in a very collaborative nature, and therefore anonymity shouldn't be expected. In other words, if you're not comfortable with other testers knowing who you are, you shouldn't participate in Canvas or its tests.
  5. If at any point you'd like to remove your account from Canvas, you're absolutely free to do so, with the exception of when you're an active tester of a physical product. In these scenarios, we typically need to retrieve the product prior to you leaving the community and erasing your personal information. Upon leaving, your personal information will be wiped completely, but you will still have access to any agreements you've already completed.

Detailed Policy

This policy describes how Centercode collects, uses, and discloses information, and the choices you have about the information we collect through Canvas. When we refer to Centercode, we mean Centercode, Inc., a California corporation. When we refer to our “Customer,” we mean Citibank, N.A. and its affiliates.

We use the Canvas site to collect, organize, and announce a wide variety of opportunities for our Customer, during which you can test the products, applications, and services of our Customer. We also use Canvas to register and collect information about Canvas Community Members (account holders) interested in participating in Customer Validation tests for our Customer.

Centercode also owns and operates the cloud-based software platform known as the Centercode Platform, the Centercode.com website, and the Betabound.com website. These services are outside of the scope of this Canvas Privacy Policy (see below under “Scope”).

You should read this entire privacy policy. If you do not agree to its terms, you should not use Canvas or submit personal information or other content to us through Canvas. By using Canvas and/or providing data to us through or related to Canvas, you are accepting and agreeing to the practices outlined in this privacy policy.

Table of Contents

Introduction

Key Terms

Key Concepts

Detailed Policy

Scope

The Data We Collect and Receive

Canvas Community Member Information

Other Information Collected

How We Use and Share Personal Data

Canvas Community Member Information

Canvas Visitor, Business and Other Contact Information

Aggregated or De-Identified Information

Other Use and Sharing

How We Share Data with Third-Party Service Providers and Partners

Cookies, IP Addresses, and Other Passive Information Collected

Centercode Mandatory Session Cookies and Usage Data

Do Not Track

Security

Updating Email Preferences or Personal Information

Removing Your Canvas Account

Data Retention

Links to Third-Party Sites

Data of Children

Changes to Our Privacy Policy

Questions or Concerns

Scope

This privacy policy describes our practices concerning the information that we collect through or related to the Canvas web-based portal, emails, and other communications related to Canvas (collectively, the Canvas Site).

This policy does not describe our privacy practices related to Centercode.com, Betabound.com, and our Centercode or Betabound social media pages (collectively, the Centercode Sites), and information we gather related to Centercode employment, vendor relationships, and business services. If you're a visitor to the Centercode Sites or a vendor, business contact, or job applicant, please visit the Centercode.com Privacy Policy to learn about the privacy practices that apply to you. If you’re a visitor to Betabound.com, please visit the Betabound.com Privacy Policy to learn about the privacy practices that apply to you.

Finally, we offer our platform to other subscribing customers that use their own instance of the Centercode Platform to develop and manage their own test communities and Customer Validation programs. Their use of our platform and the use by their authorized users is outside the scope of this privacy policy. If you encounter our platform outside of Canvas or Betabound, you should review the privacy policy of the company using our platform before creating an account. To learn more about the data that we hold and process for our customers on their behalves, including our Customer, please review our Customer Data Handling Practices.

The Data We Collect and Receive

In order to operate and enable your use of the Canvas Site, provide testing services to our Customers, operate our business, and for other legitimate business interests described in this policy, we receive and collect certain information from you and about you, including Canvas Profile information, Test Feedback, and other information, which includes Personal Data.

When we use the term Personal Data, we mean information that identifies an individual or that relates to an identified or identifiable individual (e.g. name, email address, phone number, location data, mailing address).

By submitting or providing Personal Data or other information to us, you are representing that you have authority to do so and that we have full authorization to use this information in accordance with this privacy policy, even if the information relates to other individuals or entities. You agree to provide and maintain complete and accurate information, and understand that you are solely responsible for the data that you provide to us.

Canvas Community Member Information

In order to create a Canvas Community Member account, we require you to provide both basic account information (such as your first and last name, email address, username and password, time zone, country, and date of birth), as well as Canvas Profile information (including Personal Data), such as address, phone number, gender, information about your employment, whether you are a Citi customer and if so, whether the Citi customer has credentials to log into specified portals or applications (yes/no) , and similar information). At different times, we may also ask you to complete voluntary surveys seeking more information, including Personal Data, about your interest in and qualifications for tests that may be conducted by us on behalf of our Customer. While you do not need to provide extended profile and additional information, providing additional information can increase the number of test opportunities available to you because we can match your information with the test participant requirements for specific Customer Validation tests. In addition, sometimes additional information is required in order for you to be eligible to participate in certain tests. For example, you are required to provide your address and phone number if you wish to participate in any test that involves sending a physical product to you.

We share this information as described below in “How We Use and Share Personal Data.” We call this information your Canvas Profile.

Your Test Feedback (any information that we collect or you provide during or in connection with applying for, and/or participating in a specific test) is collected by us on behalf of our Customer, which has hired us to manage its tests. We process all of this information on behalf of our Customer in accordance with our separate agreement with our Customer.

Where we process your information on behalf of our Customer and share it with our Customer, the data collection and privacy practices of our Customer (such as those disclosed in its privacy policy and any other agreement(s) you are asked to enter into with our Customer) control as between you and our Customer. For more information about the information that we hold and process for our customers on their behalves, please read about our Customer Data Handling Practices. If you have any questions about the privacy practices of our Customer, please contact our Customer about your inquiry.

Becoming a Canvas Community Member is entirely voluntary. If you do not wish to provide the required information, you should not become a Canvas Community Member. If you do not wish to provide any optional additional requested information, you should not do so.

Other Information Collected

As you interact with us regarding your Canvas account or your interest in our offerings, such as through emails and other communications outside of your Canvas account, we may gather Personal Data from you, such as your name and email address, and any other information you voluntarily provide to us.

How We Use and Share Personal Data

This section describes how we use and share information within the scope of this policy.

Canvas Community Member Information

When you provide your email to us during the Canvas registration process, you are agreeing to allow us to use the information that you provide, including Personal Data, to determine if you may match the profile for participation in Customer Validation tests conducted by or on behalf of our Customer. When we believe you might be interested in our customer’s Customer Validation tests, we will contact you about these opportunities using the contact information you have provided to us in your Canvas Profile.

We may also send you newsletters, announcements, or communications, including by email and text message, that we believe may be of interest to you. If at any time you no longer wish to receive announcements about these test opportunities or other communications, or wish to modify your account preferences, you can follow the instructions under “Updating Email Preferences or Personal Information” and/or “Removing Your Canvas Account” below to either modify your preferences or terminate your Canvas Community Member account.

When you create a Canvas account, or express interest in participating in, accept an invitation to participate in, or actually participate in a Customer Validation test being conducted by Centercode through the Canvas Site, you are agreeing to allow us to share the information you have provided to us through your Canvas registration and Canvas-related interactions, including your profile information and any other Canvas qualification survey, community survey, questionnaire, form, email or other communication about your profile, with our Customer.

We provide this data in order to enable our Customer to identify ideal test candidates and, if you are selected as a test participant, for our Customer to include this data as a part of its Customer Validation test data. Once shared with our Customer, our Customer determines its own policies and practices for the use, sharing, and disclosure of this information, and Centercode does not control how our Customer chooses to use, share, or disclose this information.

In addition to this profile information being shared with our Customer as described above, sometimes during a test, a subset may be shared with other test participants where the test includes collaborative activities, such as group chats and discussions. During these activities, selected profile information, which can include your full name, username, and any text or file-based feedback you provide in that group activity, may be visible to other participating testers. If you are not comfortable with this, do not participate in the group activity or share text or files in the group activity.

Canvas Visitor, Business and Other Contact Information

We use contact information that you have provided as a visitor to the Canvas Site or through your business or other contacts in order to contact you to discuss your interest in Canvas, and to send you information such as announcements of opportunities and events regarding Canvas and our Customer’s Customer Validation tests. Where you provide us with your contact information, we may also send you community newsletters and updates. If at any time you no longer wish to receive these communications, you can follow the instructions under “Updating Email Preferences or Personal Information.”

Aggregated or De-Identified Information

Where data is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, we may use and disclose it for any business purpose, except as otherwise prohibited under applicable law. Typically this would be used for research purposes, or to promote our community, but we may have other business uses.

Other Use and Sharing

We may also use or share information you provide to us for other legitimate interests including

  • to create an account you have requested;
  • to send administrative information to you, such as changes to our terms, conditions, and policies;
  • to respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information about our services and businesses;
  • to service your account, including maintaining records of any agreements you enter into;
  • to communicate with you and provide you with all necessary or helpful information, including on our Customer’s behalf as their service provider;
  • to send, install, remove, or retrieve any test product, device, or software on our Customer’s behalf as their service provider;
  • to personalize your experience on the Canvas Site, such as by presenting opportunities or content tailored to you;
  • regarding the general level of participation of Canvas Community Members in tests that we conduct, for our Customer to assist in determining whether the individual is a good candidate for other tests we might perform for our Customer;
  • for our internal business purposes, such as data analysis, audits, fraud monitoring and prevention, network and information security, developing new products, enhancing, improving or modifying the Canvas Site, the Centercode Platform and the Centercode Sites and services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating or expanding our business activities;
  • in connection with company transactions such as asset sales, reorganizations, mergers, joint ventures, assignments, financings, dispositions of stock, and other changes of control, where Personal Data and other information is transferred to third parties for legitimate purposes in connection with the transactions;
  • as we believe to be necessary or appropriate under applicable law, including laws outside of your country of residence, to comply with legal process, to respond to the requests of courts or governmental authorities, to enforce our terms and conditions, to protect our operations, rights, privacy, safety, customers, or property (or that of others), and to allow us to pursue available remedies or limit damages we may sustain; and
  • for other purposes you have specifically agreed to.

How We Share Data with Third-Party Service Providers and Partners

We contract with third-party service providers and partners who provide services to us in accordance with our instructions, including our cloud hosting provider for the Canvas web portal (Amazon Web Services), our web analytics provider (Google Analytics), our shipping providers (e.g. UPS, FedEx, USPS), test application distribution (e.g. TestFairy), test product installers (where you agree to allow the installation of a test product as a part of a test), and general office services such as email and file storage (Google). These third parties may have access to your data (including Personal Data) for the purpose of providing services to us and in compliance with our documented instructions. We diligently choose these third-party service providers, evaluate their privacy, security, and confidentiality practices, and enter into agreements with them specifying their obligations.

Cookies, IP Addresses, and Other Passive Information Collected

Like many companies, we use cookies (small data files stored on your computer), logging, and similar tools to collect and analyze information about our visitors and community members. This information is used to operate the Canvas Site, to prevent fraud and misuse of our services, to measure how people use the Canvas Site, to analyze how people respond to our emails and other communications, to analyze trends, to improve the Canvas Site and our services, and to improve your overall experience.  

Centercode Mandatory Session Cookies and Usage Data

When accessing your account on Canvas, the platform uses session cookies to grant you access to, and secure your account. These cookies allow us to uniquely identify you following the entry of your username and password so that you may access your account. Session cookies are required in order to use our services.

In addition, when you log in to these accounts, our servers automatically log typical HTTP information, including your Internet Protocol (IP) address, a unique device identifier (a UUID), your device name, operating system type and version, network type, country of origin, information about how you use your account (e.g. the pages you view, the links you click, the dates and times of your requests and referral URL, and other actions you take), the error messages you receive or problems you encounter, and similar data.

We use this information to provide our services and support to our Customer and users. We also use this information to monitor the regions from which you navigate your account, to identify you when you are using your account, to enhance our security and service performance, and for audit, compliance, investigations, and customer support purposes. Where requested by our Customer, we may share relevant log data with our Customer for audit, compliance, investigations, and customer support purposes.

We also use de-identified or aggregated log data gathered about the general use of our services for internal business purposes such as developing and enhancing our products and services, identifying usage trends, and for other legitimate business purposes.

Do Not Track

We do not currently respond to "Do Not Track" browser signals

Security

We take the security of the Personal Data that we hold very seriously. We maintain a written security policy for the security, integrity, and protection of the Personal Data we hold against unauthorized disclosure or loss. We have put in place physical, technical, and organizational processes and measures designed to safeguard all Personal Data. When accessing an account on Canvas via a supported web browser, Transport Layer Security (SSL/TLS) is used to protect information using both server authentication and data encryption to help ensure data is safe and secure in transit. We host Canvas, on cloud-based servers located in a secure data center environment using a firewall and other advanced technology designed to prevent interference or access from outside intruders. We also require verified email addresses, unique usernames, and strong passwords for account authentication.

These safeguards help prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to the Personal Data that we hold. However, you should be aware that no security procedures or protocols are guaranteed to be 100% secure, and there is always some risk assumed when you share information. You are responsible for maintaining the confidentiality and security of your username and password.

If you have reason to believe that your interaction with us is no longer secure, your account has been compromised, or you would like more information about our security practices, please contact us immediately. In the event that any Personal Data under our control is compromised as a result of a breach of security, we will investigate the situation and, where appropriate or required by law, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws and regulations.

Updating Email Preferences or Personal Information

If you want to opt out of receiving emails or communications from us, please contact us at citicanvas@centercode.com and we will respond promptly. Canvas Community Members may log in to their accounts to delete or amend certain types of Personal Data and information in their Canvas Profile at any time using the functionalities provided.

Removing Your Canvas Account

If you would like to remove your Canvas account entirely and stop receiving Customer Validation test announcements entirely, you can do so by contacting us at citicanvas@centercode.com. If you have another request regarding your Personal Data, please notify us at privacy@centercode.com so that we may consider and respond to your request in accordance with applicable law.

Data Retention

Unless directed otherwise by our Customer, we will retain your Personal Data for a period consistent with the original purpose of collection, including to pursue our legitimate business interests, comply with our legal obligations, resolve disputes, and enforce applicable agreements. For example, we will retain Canvas Profile information and other information collected in connection with your Canvas account as long as you maintain a Canvas account, and thereafter for the period of time that we need to pursue legitimate business interests, conduct audits, comply with and demonstrate compliance with legal obligations, resolve disputes, and enforce agreements, or as directed by our Customer.

Since we hold your data on our Customer’s behalf, we retain it in accordance with our Customer’s instructions and in accordance with our agreement with our Customer and as required by applicable law.

Deleted data stored in our backup systems will be automatically deleted within a reasonable period of time during our backup procedures, except as otherwise required by applicable law.

Links to Third-Party Sites

The Canvas Site and emails that come from us may contain links to other websites on the Internet.

Please note that we are not responsible for the privacy policies and collection, use, and disclosure practices (including the data security practices) of these third parties, including third parties that are our customers.

Data of Children

The Canvas Site is not intended for use by minors under the age of 16. We do not knowingly or specifically collect information from these minors through the Canvas Site or otherwise. If you believe that we have mistakenly or unintentionally collected information from minors or have any questions or concerns regarding the use of our services to collect information from minors, please contact us at privacy@centercode.com so that we may investigate and delete the information from our servers as necessary.

Changes to Our Privacy Policy

We reserve the right to change this privacy policy. If we make changes to this policy, you will find the revised privacy policy posted on the Canvas Site, along with the effective date of the revised privacy policy. Your use of and access to the Canvas Site and the Centercode Platform after any changes become effective will be considered your acceptance of those changes and will constitute your agreement to be bound by the new or modified privacy policy.

Questions or Concerns

Questions about this Privacy Policy or our information practices should be directed to Centercode by emailing privacy@centercode.com or by mailing us at 23332 Mill Creek Drive, Suite 260, Laguna Hills, CA 92653 ATTN: Privacy Policy.