SUMMARY AND CONTACT INFORMATION
COLLECTION AND USE OF INFORMATION
The Company is the sole owner of the information collected on our Web Platforms. The information we collect depends on what you do when you visit or utilize the Web Platforms.
We collect PII from Users in a number of different ways including, but not limited to, when Users visit our Web Platforms, register on the Web Platforms, fill out a form, and in connection with other activities, services, features or resources we make available on our Web Platforms.
We may collect, use, store and transfer different kinds of PII about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, profile picture, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Location includes IP Addresses, geolocation, beacon based location, and GPS location. You may disable our use of certain location data through your device or browser settings, for example by disabling “Location Services” for any applicable application in iOS privacy settings.
- User generated Content include comments or messages provided in free text boxes
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also may collect, or direct one of our partners to collect, your financial information to facilitate payment by a third party sponsor.
Please note that we do not collect PII about you unless you choose to provide such PII to us by creating an account, subscribing to our services, and/or contacting us regarding the Web Platforms or our products and services. If at any time you do provide us with such PII, we will collect it.
Analytical Information and Anonymized Data
For each User, we may automatically gather certain information and store it in log files. This information includes the following: web beacons, embedded web links, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We may collect and store this information on an individual basis and in aggregate, or combined, form. We may also collect both User-specific and aggregate information on what pages Users access or visit. We use this information to analyze trends, to administer the Web Platforms, to track Users’ movements around the Web Platforms, and to gather demographic information about our user base as a whole. We also use this information to improve the content of our web pages, and to customize the content and layout of our pages. All of this is done with the intention of making our Web Platforms more useful to Users.
We use session cookies to make it easier for you to navigate the Web Platforms. In particular we use session cookies to record session information, such as which web pages a User has visited, and to track User activity on the Web Platforms. We also use session cookies to store any passwords used on the Web Platforms (such as a password associated with a User account), so you do not have to enter it more than once per session. Session cookies expire when you close your browser.
We use persistent cookies to track and target the interests of our Users to enhance the experience on our Web Platforms. Persistent cookies remain on your device for an extended period of time. You can remove persistent cookies by following directions provided in your browser’s “help” file.
Use of PII by the Company
We will use information in connection with the purpose for which you provided it (e.g., to contact you with a response to a request for information, to provide products or services, and/or to contribute to customer surveys). We will communicate with you by email, telephone, or social media, in accordance with your wishes.
Generally, the Company uses this information for internal record keeping however, the Company may also use your PII to send you information on products, services, and special offers and promotions in which you might have an interest. From time to time, we may also use your information to contact you for market research purposes. The means by which the Company will use to contact you with this information will depend on the type of PII you have provided. For example, if you provide us with your email address, you may receive periodic promotional emails from us.
If you do not wish to receive special offers and other promotional information from us, you may opt out of receiving such communications, as discussed below.
Sharing Your PII
The Company will not disclose any of your PII to third parties without your permission or as described below.
We may also disclose any collected information, including PII, if: (1) the disclosure is necessary or useful to our provision of services; (2) we believe in good faith that disclosure is necessary to protect our rights, interests, or property; (3) we are acting in good faith to protect your safety or the safety of others, to investigate fraud, or to respond to a government request; (4) we believe in good faith the disclosure is required by law, such as to comply with a subpoena, search warrant, court order, or similar legal or administrative process; and (5) a third party purchases or otherwise acquires us or the Web Platforms, in which case your information will likely be among the assets transferred.
The Web Platforms may offer opportunities to request additional information from sponsors or the Company’s partners. By requesting more information, you give the Company permission to transfer your PII to the sponsor or partner so they can fulfill your request. In many instances, only your e-mail address will be shared.
We do not rent or sell email addresses to third parties, or otherwise share any non-anonymized personally-identifying information we collect, with any third parties (other than our affiliated entities) except as set forth above.
If we do share PII with an entity working on our behalf, we will employ commercially-appropriate procedures to help ensure that the disclosed PII is used only for authorized purposes by authorized persons, and that safeguards are in place to help maintain the security, integrity, and privacy of the PII.
Upon request we provide Web Platform Users with access to their own contact PII (e.g., name, address, e-mail address, phone number) that we maintain about them. You can access this PII by sending your request to: email@example.com. To help us process your request, please provide sufficient information to allow us to identify you in our records.
We reserve the right to ask for information verifying your identity prior to disclosing any information to you. Should we ask for verification, the information you provide to verify your identify will be used only for that purpose, and all copies of this information in our possession will be destroyed when the process is complete.
We also offer Users the opportunity to have inaccuracies corrected in all information we maintain about them. To begin the process, email: firstname.lastname@example.org. Please provide sufficient information to allow us to identify you in our records and help us process your request.
YOUR ABILITY TO CONTROL YOUR PII
If you do not wish to receive promotional emails from us, please let us know by using the opt-out response device that can be found at the bottom of every email we deliver or by emailing us at email@example.com. To help us process your request, please include sufficient information for us to identify you in our records (your email address will suffice). Please allow a reasonable time for us to process your request.
If you do not wish for us to share your PII with any third parties working on our behalf to serve our Customers, please let us know by sending your request to firstname.lastname@example.org. To help us process your request, please provide sufficient information to allow us to identify you in our records. Please allow a reasonable time for us to process your request. Please note that exercising these opt-out rights may limit your ability to receive the full range of the Company’s products and services.
Please note that, although you can opt not to receive promotional messages, we reserve the right to send you informational email messages about any administrative notices regarding the Web Platforms, as permitted under the CAN-SPAM Act (15 U.S.C. §7701 et seq.).
If you are a resident of certain jurisdictions, you may also have the right to opt-out of any current or futures sale of your PII. To exercise this right in accordance with applicable law, please contact us at the following email address: email@example.com and write “Opt Out of the Sale of Personal Information” for the subject of your message. We reserve the right to ask for information verifying your identity and residency prior to disclosing any information to you or acting on your request. Should we ask for verification, the information you provide to verify your identity and residency will be used only for that purpose, and all copies of this information in our possession will be destroyed when the process is complete.
The security of your PII is important to us. We follow generally accepted industry standards and have put in place suitable physical, electronic, and administrative procedures to protect the PII submitted to us, both during transmission and once we receive it, and to guard that PII against loss, misuse or alteration. When you enter sensitive and/or PII on our registration or order forms, we encrypt that PII using secure socket layer technology (SSL).
Please note, however, that no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we use commercially-reasonable means to protect your PII, we cannot guarantee its absolute security.
The Company does not offer its services or promote its Web Platforms to, nor does it intentionally collect or retain PII from, children who are younger than 18 years of age. Web Platforms Users are cautioned, however, that the collection of PII submitted in an e-mail or through the Web Platforms will be treated as though it was submitted by an adult, and may, unless exempted from access by Federal or State law, be subject to public access. If you believe your child may have submitted PII to the Company without indicating their actual age and would like it removed, please contact us at firstname.lastname@example.org and we will delete it immediately.
CALIFORNIA PRIVACY RIGHTS
Under California’s “Shine the Light” law, California residents who provide PII in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once per calendar year, information about the Customer PII we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of Customer PII and the names and addresses of those businesses with which we shared Customer PII for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding 2018 sharing activities). To obtain this information from us, please contact us at the following email address: email@example.com and write “Request for California Privacy PII” for the subject of your message. We will send you a reply e–mail within 30 days containing the requested information once we confirm your request. Not all information sharing is covered by the “Shine the Light” requirements and only that information which is covered will be included in our response.
DO NOT TRACK DISCLOSURES
Some web browsers may transmit “do-not-track” signals to Web Platforms with which the browser communicates. Our Web Platforms do not currently respond to these “do-not-track” signals.
THIRD PARTY WEBSITES
From time to time, the Web Platforms may link you to other websites or applications (“Linked Websites”) that are not owned by the Company. We do not control the collection or use of any information, including PII, which occurs during your visit to the Linked Websites. Further, we make no representations about the privacy policies or practices of the Linked Websites, and the Company is not responsible for the privacy practices of these Linked Websites.
Be careful of disclosing any of your PII when leaving our Web Platforms. We encourage you to be aware when you leave our Web Platforms and to read the privacy statements of each and every website that collects PII.
CHANGES TO THIS POLICY
From time to time, we may use your PII for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change materially at some time in the future, we will post the policy changes to our Web Platforms. If we have collected PII from you, we will notify you about the changes prior to making use of your information in new ways and will provide you with a reasonable opportunity to opt out of the new procedures before they are implemented. We will also honor opt out requests made following implementation of the new procedures, as discussed above.
If you believe that our Web Platforms are not following our stated policy, you may contact us at the above address.