WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?
- Information You Voluntarily Submit to the Website: The Website may collect personal information from you such as your name or email address. For example, you may voluntarily submit information to the Website by leaving a comment, subscribing to a newsletter, or submitting a contact form. Personal Data may include, but is not limited to, your name, email address and phone number.
- Information We Collect from Others: The Website may receive information about you from other sources. For example, if you use a third-party software through the Website, they may transfer information to us for fulfillment. We do not control the data privacy or protection policies of third parties, and we are not responsible for the privacy practices of these third parties. Our legal basis for processing this information is our legitimate interests, namely monitoring and improving our services, and the legitimate interests of our customers.
- Automatically-Collected Information: The Website automatically collects certain information about you and the device with which you access the Website. For example, when you use the Website, The Website will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Website. The Website may also collect information about actions you take when using the Website, such as links clicked.
- Cookies: The Website may log information using cookies, which are small data files stored on your browser by the Website. The Website may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the Website.
HOW YOUR INFORMATION MAY BE USED
We may use the information collected in the following ways:
- To operate and maintain the Website;
- To fulfill orders or oversee contests or promotions;
- To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings;
- To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
- To respond to your comments or inquiries;
- To provide you with user support;
- Training and quality control;
- To track and measure advertising on the Website; or,
- To protect, investigate, and deter against unauthorized or illegal activity.
LEGAL BASES FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)
We are responsible as a “controller” of your Personal Data under the GDPR and below are the types of lawful basis that we will rely on to collect and process your Personal Data:
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at email@example.com.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
- Consent means where you have consented to a certain use of your Personal Data.
- Vital Interest means processing your Personal Data to protect the vital interests of the data subject or another natural person.
How to File a GDPR Complaint
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
WHERE YOUR PERSONAL DATA IS HELD
Personal Data may be held at our offices and those of our affiliates, parent or related companies, third party Personal Data may be held at our offices and those of our affiliates, parent, or related companies, third party agencies, service providers, representatives and agents as described below (see below: “Third Party Use of Personal Information”).
THIRD-PARTY USE OF PERSONAL INFORMATION
Company may share your Personal Data with certain third parties as set forth below:
Third Party Vendors: We may share your information with third party vendors or service providers who help us provide our products or services or the Website, including database hosting and data processing services, and assist us in responding to requests by you for information that you request.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. We may also share Personal Data with potential buyers. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Third Parties with Permission: We may share your information with third parties to whom you ask us to send your information.
Agents, Consultants, and Related Third Parties: Company, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the Website or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our customer contracts.
The Website may share your information with third parties when you explicitly authorize us to share your information. Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies.
At this time, your personal information is not shared with any other third-party service providers. This list may be amended from time to time in the Website’s sole discretion.
Except when required by law, Company will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, Company may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
From time to time, Company may use anonymous data, which does not identify you alone, or when combined with data from other parties. This type of anonymous data may be provided to other parties for marketing, advertising, or other uses. Examples of this anonymous data may include analytics or information collected from cookies.
What are cookies?
A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website. The cookie will collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Website via a link from third party site, the URL of the linking page.
In addition to cookies, the Website may use web beacons. Web beacons allow us to count the number of users who have visited or accessed the Website and to recognize users by accessing our cookies. We may employ web beacons to facilitate Website administration and navigation, to track the actions of users of the Website, to compile aggregate statistics about Website usage and response rates, and to provide an enhanced online experience for visitors to the Website. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color. A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF, and tracker GIF.
What are the different types of cookies and how do we use them?
- Essential – These are cookies which are essential for the running of the Website. Without these cookies, parts of the Website would not function. These cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.
Examples of how we may use essential cookies include:
- Setting unique identifiers for each unique visitor, so that Website numbers can be analyzed.
- Functional – These cookies are used to remember your preferences on the Website and to provide enhanced, more personal features. The information collected by these cookies is usually anonymized, so we cannot identify you personally. Functional cookies do not track your internet usage or gather information which could be used for selling advertising.
Examples of how we may use functional cookies include:
- Gathering data about visits to the Website, including numbers of visitors and visits, length of time spent on the Website, pages clicked on or where visitors have come from;
- Eliminating the need for returning users to re-enter their login details.
- Analytical Performance – Analytical performance cookies are used to monitor the performance of the Website, for example, to determine the number of page views and the number of unique users our Website has. We use this information to improve user experience or identify areas of the Website which may require maintenance. The information is anonymous (i.e., it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.
- Examples of how we may use analytical cookies include:
- Measuring users’ behavior;
- Analyzing which pages are viewed and how long for and which links are followed to better develop the Website.
- Examples of how we may use analytical cookies include:
- Advertising – Behavioral advertising cookies, which may be placed on your device by us or our trusted third-party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make advertising on websites more relevant to you. Although behavioral advertising cookies can track your activity around the internet, these cookies cannot identify you personally.
Examples of how we may use advertising cookies include:
- Providing advertising to you and enabling us to manage our relationship with those advertisers by, for example, tracking how many unique users have seen a particular advertisement or followed a link in an advertisement.
- Third Party Cookies – You may notice on some pages of the Website that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own cookies on your device. We do not control the use of these third party cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party who originally set them. Please check the third party websites for more information about these cookies.
Users may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of your internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. However, if you deactivate the setting of cookies in your Internet browser, not all functions of our Website may be entirely usable.
How can you manage or opt-out of cookies?
Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control cookies. In some cases, you can choose to accept cookies from the primary site, but block them from third parties. In others, you can block cookies from specific advertisers, or clear out all cookies. Deleting or blocking cookies may reduce functionality of the Website. To learn more about how to reject cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted cookies, you should contact the supplier of your web browser.
Opting out of Analytical Performance Cookies
If you would like to opt out of Analytics cookies, please do so by clicking on the links below:
- Google Analytics: https://tools.google.com/dlpage/gaoptout.
Opting out of Behavioral Advertising Cookies
If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps or use the platform controls on your mobile device to opt out.
First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at www.allaboutcookies.org/manage-cookies/.
Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site.
Sponsored Content Tracking Pixels
This Website may engage in sponsored campaigns with various influencer networks, brands, and agencies. All sponsored content is duly disclosed in accordance with the FTC’s requirements. From time to time, these sponsored campaigns utilize tracking pixels (aka web beacons), which may contain cookies to collect data regarding usage and audience. This information is collected by the sponsoring company to track the results of the campaign. As stated above, these pixels may capture your IP address on behalf of the content sponsor. No personally identifiable information collected by the Website is used in conjunction with these tracking pixels.
On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, Company may see if and when you open an email and which links within the email you click. Also, this allows Company to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.
HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT
We will keep your personal information while you have an account with us, or we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf.
- To show that we treated you fairly.
- To keep records required by law.
RIGHTS RELATED TO YOUR PERSONAL INFORMATION
Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated within a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.
We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.
Opt-out – If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications. You may also notify us at firstname.lastname@example.org to be removed from our mailing list.
Access – You may request access to the personal information we have about you by submitting a request to email@example.com
Amend – You may contact us at firstname.lastname@example.org to amend or update your personal information.
Forget – In certain situations, you may request that we erase or forget your Personal Data. To do so, please submit a request to email@example.com.
Please note that we may need to retain certain information for record keeping purposes or to complete transactions, or when required by law.
Access and Disclosure
You may make a verifiable request that we disclose the categories of personal information we have collected about you, the categories of sources of the personal information we collected about you, the business or commercial purpose for collecting or selling the personal information, the categories of third parties with whom we share your personal information, our use of the personal information and if the personal information was disclosed or sold to third parties, including the categories of personal information sold or disclosed. You also have the right to make a verifiable request for a copy of the personal information collected about you for the twelve (12) months prior to the date of your request. To see any categories of personal information we have sold in the last twelve (12) months or opt out of the sale or disclosure of personal information, please refer to the Do Not Sell My Personal Information link on each page of this Website. Please note that we are not required to:
- Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information.
Deletion Request Rights
You have the right to request that Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the personal information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Children Under 16
We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your Rights
To exercise the access, disclosure and deletion rights described above, please submit a verifiable request to us by emailing firstname.lastname@example.orgAttn: CCPA.
You may only make a verifiable request for access or disclosure twice within a twelve (12) month period. You may also make a verifiable consumer request on behalf of your minor child. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
To respond to your request or provide you with personal information, Company must verify your identity or your authority to make the request. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request. For instructions on exercising sale opt-out rights, please refer to the Do Not Sell My Personal Information link on each page of this Website.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorise personal information sales. However, you may change your mind and opt back in to personal information sales at any time by e-mailing us at email@example.com Consumers who opt-in to personal information sales may opt-out of future sales at any time.
We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
SENSITIVE PERSONAL INFORMATION
The Website does not knowingly collect any personally identifiable information from children under the age of 16. If a parent or guardian believes that the Website has personally identifiable information of a child under the age of 16 in its database, please contact us immediately at firstname.lastname@example.org and we will use our best efforts to promptly remove such information from our records.
THE PARTIES WAIVE ANY RIGHT TO ASSERT ANY CLAIMS AGAINST THE OTHER PARTY AS A REPRESENTATIVE OR MEMBER IN ANY CLASS OR REPRESENTATIVE ACTION, EXCEPT WHERE SUCH WAIVER IS PROHIBITED BY LAW OR DEEMED BY A COURT OF LAW TO BE AGAINST PUBLIC POLICY. TO THE EXTENT EITHER PARTY IS PERMITTED BY LAW OR A COURT OF LAW TO PROCEED WITH A CLASS OR REPRESENTATIVE ACTION AGAINST THE OTHER, THE PARTIES AGREE THAT: (I) THE PREVAILING PARTY SHALL NOT BE ENTITLED TO RECOVER ATTORNEYS’ FEES OR COSTS ASSOCIATED WITH PURSUING THE CLASS OR REPRESENTATIVE ACTION (NOT WITHSTANDING ANY OTHER PROVISION IN THIS AGREEMENT); AND (II) THE PARTY WHO INITIATES OR PARTICIPATES AS A MEMBER OF THE CLASS WILL NOT SUBMIT A CLAIM OR OTHERWISE PARTICIPATE IN ANY RECOVERY SECURED THROUGH THE CLASS OR REPRESENTATIVE ACTION.
LINKS TO OTHER WEBSITES
OTHER TERMS AND CONDITIONS
Your access to and use of the Website may also be subject to any separate agreements or terms and conditions you have signed or agreed to with Company. Please refer to those agreements as needed.
Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.
The Website collects the following data using a cookie when serving personalized ads:
- IP Address
- Operating System type
- Operating System version
- Device Type
- Language of the website
- Web browser type
- Email (in hashed form)
If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
Last updated: September 26, 2022.