Effective Date: July 2016

Purpose. The purpose of this Privacy Policy is to describe how Bertram Communications LLC (DBA Powercode) (“Powercode”) collects, uses and shares information about you through our U.S. online interfaces (e.g., websites and mobile applications) owned and controlled by us, including billing.powercode.com and v9central.powercode.com (collectively referred to herein as the “Site”). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us or as described at the end of this Policy.

Our Privacy Policy explains:

• Information That We Collect
• How We Use and Share Your Information
• Access to Your Information and Choices
• Security of Your Information
• Consent to Data Processing in United States
• Changes to Our Privacy Policy
• Questions and How to Contact Us

Scope; Third Party Sites. Our Site also contains links to third party sites that are not owned or controlled by Powercode. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal information.

Terms of Use. Please note that your use of our Site is also subject to our Terms of Use.

Information You Provide Us

We collect information you provide to us, for example when you create or modify your account, register to use our Site, purchase products or services from us, request information from us, contact customer support, or otherwise communicate with us. This information may include:

• Name
• Home, work, billing, and shipping addresses
• Email address
• Home, work, and mobile telephone numbers
• Credit card number (solely for payment purposes)
• Bank or other account number
• Date of Birth (DOB)

Information We Collect Through Your Use of our Site

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads on our Site, but they will not be based on how you browse and shop.

Information Collected Through Cookies and Similar Technologies

We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the Site again, the cookie allows the Site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends and providing relevant advertising to you (see the “Advertising” section below.)

Geolocation Data

If you are under the age of 13, please do not attempt to register with us at this Site or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 13, please Contact Us or call us at (920) 351-1010.

To Provide Products, Services, and Information. We collect information from you so that we can provide information that you request from us. We may send you newsletters, and information about our products, services, promotions, and new offerings.

Sharing with Third Parties. We may share your personal information with third parties who may contact you about their products and services that may be of interest to you.

Advertising. We may use how you browse our website in order to show you ads for Powercode or our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our site or third-party sites not owned by Powercode.

We use Google AdWords Remarketing to advertise our services across the Internet and to advertise on third party websites (including Google) to previous visitors to our Site. AdWords remarketing will display ads to you based on what parts of our Site you have viewed by placing a cookie on your web browser. It could mean that we advertise to previous visitors who haven’t completed a task on our site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our Website, so that they may show you ads relating to that page. If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google’s Ads Preferences Manager at https://www.google.com/settings/ads.

Your Consent. In addition to the sharing described elsewhere in this Policy, we will share personal information with companies, organizations or individuals outside of Powercode when we have your consent to do so. You may not provide us with any sensitive personal information. Sensitive personal information is a particular category of personal information such as confidential medical facts and health information, racial or ethnic origins, political or religious beliefs or sexuality.

Legal Proceedings. We will share personal information with third party companies, organizations or individuals outside of Powercode if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, subpoena, legal process or enforceable governmental request.
• Enforce applicable Terms of Use, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of Powercode, our users, customers or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

If you have questions about personal information we have about you or need to update your information, you can Contact Us or call us at (920) 351-1010. You can opt-out of receiving marketing and promotional e-mails from Powercode by emailing us at support@powercode.com, and by using the opt-out or unsubscribe feature contained in the e-mails.

You can close your online account by calling us at (920) 351-1010. If you close your account, we will no longer use your online account information or share it with third parties. We may, however, retain a copy of the information for archival purposes, and to avoid identity theft or fraud.

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

If you are a resident of the European Economic Area (EEA), in order to provide our Site, products and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the EEA, including to the United States. Accordingly, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as within the EEA to the extent feasible under applicable law. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us, email us at support@powercode.com, call us at (920) 351-1010, or contact us by US postal mail at the following address:

Bertram Communications LLC
DBA Powercode
300 Industrial Drive
Random Lake, WI, 53075 US