Effective date: June 11, 2020
- How to contact us.
- The information we collect about you.
- How we may use your information.
- Who we may share your information with.
- How we safeguard your personal information.
- How long we store your personal information.
- Your rights and options regarding your personal information.
- Special notice to non-U.S. users regarding data transfers.
- Sensitive Information.
- Governing law and jurisdiction.
1. HOW TO CONTACT US
You can update your preferences and information by updating your contact information through our Services or contacting us at the e-mail address or phone number below. Additionally, if you have any questions or concerns about our use of your Personal Information (defined below) or wish to communicate with our senior security official and senior privacy official, please do not hesitate to contact us through any of the methods below.
2. PERSONAL INFORMATION
While using our Services, we may ask you to provide us with certain personally identifiable information (“Personal Information”). Personal Information is information that identifies, relates to, describes, can reasonably be associated with, or can reasonably be linked to a particular individual or household.
We collect information from you both when you provide it voluntarily and also automatically when you use our Services. We may also collect Personal Information from other sources, as described below.
We collect Personal Information from you and any devices (including mobile devices) you use when you use our Services, provide us information on a web form or when you otherwise correspond with us. Please remember that any information that is disclosed in public comments, forums or other areas enabling other users to submit comments (“Forums”) becomes public information, is not maintained or treated as confidential, and you should exercise caution when deciding to disclose your Personal Information.
In addition, we also collect Personal Information about you from third parties in connection with our Services, including from the following sources:
- Our customers when we provide services for our customers
- Service providers (including hosting providers)
- Data analytics service providers
INFORMATION WE COLLECT ABOUT YOU
We may collect the following categories of Personal Information from you, depending on your interactions with our Services and the choices you make, as further described in the chart below:
- Identifiers. Your name, email address postal address, unique personal identifier, and Internet Protocol (IP) address.
- Internet or other electronic network activity information. For example:
- Browse history. Data about the webpages you visit.
- Search history. Data about the search terms you enter.
- Device, connectivity, and configuration data. Data about your device and nearby networks, including regional and language settings.
- Geolocation data. Data about your device’s location, which is inferred from your IP address and your postal address.
- Demographic data. Data about you such as your age, country, preferred language and other data reflecting your consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Information collected through use of our Services
|Categories of Information||Description of category||How We Use Information||Legal basis for the processing purpose|
|Third Party Data||This includes both Personal Information and non-personally identifiable data from our affiliates, customers, partners or vendors, data brokers or public sources.||
|Location Information||We may collect general location information if you use features on our Services that provide location-based services.||
This can be Personal Information and non-Personal Information that is collected about you when you are using our Services, and this may include:
Cookies. Cookies are small data files that are downloaded onto your computer or mobile device when you use our Services, which are unique to your device or account. Cookies make it easier for you to use our Services by saving your preferences so that we can use these to improve your next and subsequent visits to our Services. Cookies help us learn which areas of our Services are useful and which areas need improvement.
Cookies may be either persistent or temporary (or session) cookies. A persistent cookie retains user preferences for a particular website, app or service, allowing those preferences to be used in future use sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). A temporary cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Pixels, Web Beacons. We or third party partners may use invisible pixels or beacons on our Services to count how many users access or use certain pages, features or content. This information is collected and reported in the aggregate. We may use this information to improve our current Services offerings, develop new products or services, and target information to you that may be helpful and useful to you based upon your use of our Services.
|Anonymized Information||We use anonymized and aggregated information that may be created or derived from your Personal Information or usage of our Services for purposes that include data analysis, improving our Services, advertising, and developing new features and functionality within our Services.||
3. HOW WE MAY USE YOUR INFORMATION
We will only use your information for the purposes identified above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose described here. If we need to use your Personal Information for an unrelated purpose or if we change the basis on which we are processing your data, we will notify you and we will explain the legal basis which allows us to do so.
Where we rely on “legitimate business interests” as the reason for processing your information, we have determined, acting reasonably and considering the circumstances, that we are able to process your Personal Information in accordance with data protection laws on the basis that we have a legitimate business interest.
We have a legitimate business interest in processing your Personal Information as:
- We need the information to respond to your inquiries;
- We need the information to send you information; and
- We would be unable to provide our Services without processing your information.
We consider that it is reasonable for us to process your Personal Information for the purposes of our legitimate interests outlined above as (a) we process your Personal Information only so far as is necessary for such purpose and (b) it can be reasonably expected for us to process your Personal Information in this way. In most cases, the information is being processed for your benefit as well as ours.
If we wish to process your existing information for a new purpose other than as stated above, and you are located in the European Union, California or any other jurisdiction that has passed a similar data privacy law, we must inform you of that further processing and provide information surrounding your information’s use.
4. SHARING YOUR INFORMATION
We share non-Personal Information with third parties at our discretion. We do not sell your Personal Information or share your Personal Information for our commercial benefit. In connection with our Services, we may share your Personal Information with certain third parties who we engage to help us run our business and perform the services, including under the following circumstances:
- Software and service providers we use to manage and process your information.
- Affiliates, subsidiaries, and clients.
- Google Analytics, a service provided by Google, Inc., to gather information about how you and other users engage with our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners.
- Other third parties that you expressly request us to share your Personal Information with.
Additionally, we will share your Personal Information with third parties where required by law, where it is necessary in connection with our Services or products, or where we have another legitimate interest in doing so.
Most of the third parties with whom we share your Personal Information are located and store your information in the United States, although some may be located or store your information outside of the United States.
If we are subject to a merger or acquisition with/by another company, we may share information with them in connection with the transaction.53.
5. HOW WE SAFEGUARD YOUR INFORMATION
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of Personal Information is at your own risk.
6. HOW LONG WE STORE YOUR INFORMATION
We also will retain Usage Information for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when Usage Information is used to strengthen the security or to improve the functionality of our Services or products, or we are legally obligated to retain Usage Information for longer periods.
7. YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION
Marketing Preferences. You can opt out from receiving future marketing communications from us at any time by using the unsubscribe function in the email you receive from us, or contacting us as set forth under “How to contact us” above. Please allow sufficient time for your preferences to be processed. Even if you opt out of receiving marketing messages, we may still contact you for transactional purposes like confirming or following up on a service request, or asking you to review a service you have used. If you later opt back into getting marketing communications from us, we will remove your information from our opt-out databases.
As noted above in “The Information We Collect About You,” you can choose whether to accept cookies by changing the settings on your browser or device. However, if you choose to disable cookies, your experience with our Services may be impaired and some features may not work as they were intended.
If you are located in the European Union, you have the following rights with respect to your data under certain circumstances:
- The right to request access to your Personal Information and the following information regarding our use of your Personal Information:
- The purpose of such use
- The categories of your Personal Information that we have used
- Who we have disclosed your Personal Information to
- The right to request us to correct any inaccurate Personal Information concerning you.
- The right to request us to erase your Personal Information when we no longer need such data in connection with our services or, with respect to “special categories” of Personal Information, if you withdraw consent to our use of such information.
- The right to withdraw consent to our use of Personal Information, if we are relying on consent to use your Personal Information.
- The right to request us to restrict our use of your Personal Information (e.g., suspend our use of your Personal Information).
- The right to object to our use of your Personal Information where we are not using it to perform Services you have requested from us.
- The right to receive a copy of your Personal Information.
- The right to lodge a complaint with the supervising authority of your country.
If you want to exercise any of the rights listed above, please contact us through one of the methods listed in Section 1 above.
If you are located in the United States, depending on where you live, you may have certain rights with respect to Personal Information that we have collected and used under certain circumstances, which may include the following:*
- The right to request the following information regarding our use of your Personal Information:
- The categories of your Personal Information that we have collected
- The purposes for which we have collected or used such Personal Information
- The categories of sources for the Personal Information we have collected about you
- The categories of third parties with whom we have disclosed your Personal Information
- If we have disclosed your Personal Information for a business purpose, a list identifying the Personal Information categories that each category of recipient obtained
- If we have sold your personal information, a list identifying the Personal Information categories that each category of recipient purchased
- The right to receive a copy of your Personal Information.
- The right to request us to erase your Personal Information when we no longer need such data in connection with our Services (subject to certain exceptions that may apply under applicable law).
If you choose to exercise your CCPA rights, we will not charge you different prices or provide different qualify of services unless those differences are related to your personal information or otherwise permitted by law.
* If you are a resident of a jurisdiction where one or more of these rights are granted to you under applicable law, and you wish to exercise any such rights listed above, please contact us by either:
· Phone: 1-877-819-2188
· Email: firstname.lastname@example.org
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. Please understand that we are required to verify your request and may require you to provide some information to enable us to carry out such verification. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
8. TRANSFER OF DATA; SPECIAL NOTICE TO NON-U.S. USERS
9. SENSITIVE PERSONAL INFORMATION
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal information as this term is defined under applicable data protection and privacy laws (for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
10. POLICY ON CHILDREN’S INFORMATION
Our Services are not created for anyone under the age of 13 (“Children” or “Child”). By using the Services, you represent that you are at least 13 years old. If you do not meet this age requirement, then you must not access or use our Services.
We do not knowingly collect personally identifiable information from anyone under the age of 14, and we do not target the Services to children under the age of 13. If you are a parent or guardian and you are aware that your Child has provided us with Personal Information, please contact us though one of the methods listed under “How to Contact Us”, above. If we become aware that we have collected Personal Information from Children without verification of parental consent, we take reasonable steps to remove that information from our servers.
For more information about the Children’s Online Privacy Protection Act (“COPPA”), which applies to websites that direct their services to children under the age of thirteen (13), please visit the Federal Trade Commission’s website.
11. LINKS TO OTHER SITES
12. GOVERNING LAW AND JURISDICTION