Effective November 18, 2022
WHO WE ARE
SCOPE & ACKNOWLEDGEMENT
Your use of our Services indicates your acknowledgement of the practices described in this Policy.
If you are a customer (“Customer”), you may be subject to additional terms relating to your use of the Services, such as a Sales Contract or Purchase Contract.
COLLECTION AND USE OF PERSONAL DATA
Personal Data We Collect
In order to provide our Services, we may collect and process information that relates to identified or identifiable individuals and households (“Personal Data”). We collect and process the following categories of Personal Data (note, specific Personal Data elements are examples and may change):
Personal Data about you and your identity, such as your name, and other Personal Data you may provide on registration forms.
Contact Data: Identity Data used to contact an individual, e.g. email address, physical address, or phone number.
Device Data: Personal Data relating to your device, browser, or application e.g. IP addresses, MAC addresses, application ID/AdID/IDFA, identifiers from cookies, session history and similar browsing metadata, and other data generated through applications and browsers, including via cookies and similar technologies.
User Content: Personal Data included in content provided by Users of the Service in any free-form or unstructured format, such as in a “contact us” box, free text field, in a photo, file or document, or messages.
How We Collect Personal Data
We collect Personal Data from various sources based on the context in which the Personal Data will be processed:
You: We collect Personal Data from you directly, for example, when you input information into an online form, sign up for a list, or contact us directly.
Your Devices: We may collect certain Personal Data automatically from your devices. For example, we collect Device Data automatically using cookies and similar technologies when you use access our Sites or when you open our marketing communications.
Customers: We may process Personal Data from our Customers with whom we have a relationship, and who may provide us, or grant us access to systems providing, information about Users, personnel, account information, etc.
Service Providers: We receive Personal Data from third parties with whom we have a relationship in connection with their performance of services or processing of transactions on our behalf.
Contractors: We may receive Personal Data from individuals to whom we make available Personal Data for a business purpose pursuant to a written contract.
Data we create: We (or third parties operating on our behalf) create and infer Personal Data based on our observations or analysis of other Personal Data we process, and we may correlate this data with other data we process about you.
How We Process Personal Data
When you use our Service, we automatically collect and process Device Data and Usage Data. We use this data as necessary to initiate or fulfill your requests for certain features or functions through our Service, such as delivering pages, logging activities for security purposes, etc.
We may process Identity Data, Device Data and Contact Data in connection with email marketing communications (such as promotional emails), which you might receive if you choose to receive marketing communications or engage in a transaction allowing us to send you marketing communications. We may also automatically collect Device Data when you open or interact with those marketing communications.
Subject to Users’ rights & choices, we use Identity Data and Contact Data as necessary to customize, deliver, and otherwise process marketing communications, and in order to tailor certain communications to individuals’ preferences and requests. Additionally, we may process Device Data from devices receiving those marketing communications as part of our business interests in understanding whether our emails are opened or other aspects of engagement with such marketing communications.
Feedback and Surveys
We generally process Identity Data, Contact Data, and User Content collected in connection with Customer surveys or questionnaires. We generally process this Personal Data as necessary to respond to Customer requests/concerns, to create aggregate analytics regarding customer satisfaction and customer business practices, and to improve our services. We may also store and analyze feedback for our purposes, for example, to personalize our Service.
When you contact us though the Services using a “contact us” box or via email, we process Personal Data such as Identity Data, Device Data, and any Personal Data contained within any User Content. We use Identity Data, Contact Data, and User Content as necessary to communicate with you about the subject matter of your request and related matters. We may use such Personal Data for marketing purposes where permitted by local laws (see below) and relevant to the subject matter or your inquiry.
Cookies and Similar Tracking Technologies
We, and certain third parties, automatically collect and process Identity Data, Usage Data, and Device Data when you interact with cookies and similar technologies on our Services. We may receive this data from third parties to the extent allowed by the applicable partner. Please note that the privacy policies of third parties may also apply to these technologies and the Personal Data collected through them.
Subject to your rights & choices, we may use this information as follows:
- for “essential” or “functional” purposes, such as to enable certain features of the Services;
- for “analytics” and “personalization” purposes, consistent with our business interests in analyzing Users’ use of the Sites, or use by the Customer on whose behalf you use the Services. We use this data to understand how Users and Customers use the Service, how the Service performs, how Users engage with and navigate through the Service, referral sites or URLs, how often they visit our Site, and other similar information, as well as to tailor the Service based on geographic location, and understand characteristics of Users in certain locations.
Note: Some of these technologies can be used to identify you across platforms, devices, sites, and services.
Business Purposes of Processing
In addition to the processing described above, we generally process any Personal Data we collect or create for several common business purposes. For example, we process your Personal Data as follows:
Operate our Services and Fulfill Obligations
We process any Personal Data as is necessary to provide the Services, and as otherwise necessary to fulfil our obligations to you, e.g. to provide you with the information and services you request.
Internal Processes and Service Improvement
We may use any Personal Data we process through our Services as necessary in connection with our improvement of the design of our Services, understanding how our Services are used or function, for customer service purposes, in connection with the creation and analysis of logs and metadata relating to service use, and for ensuring the security and stability of the Services. Additionally, we may use Personal Data to understand what parts of our Service are most relevant to Users, how Users interact with various aspects of our Services, how our Services perform or fail to perform, etc., or we may analyze use of the Services to determine if there are specific activities that might indicate an information security risk to the Services or our Users. This processing is subject to Users’ rights and choices.
We process Personal Data as necessary in connection with our creation of aggregate analytics relating to how Customers, and Users use our Services, such as the products and services used, service delivery metrics, Customer trends, and to create other reports regarding the use of our Services and other similar information and metrics. The resulting aggregate data will not contain information from which and User, or Customer may be readily identified.
Compliance, Safety & Public Interest
Note that we may, without your consent or further notice to you, and to the extent required or permitted by law, process any Personal Data subject to this Policy for purposes determined to be in the public interest or otherwise required by law. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest or as required by a public authority. Please see the data sharing section for more information about how we disclose Personal Data in extraordinary circumstances.
Other Processing of Personal Data
If we process Personal Data in connection with our Services in a way not described in this Policy, this Policy will still apply generally (e.g. with respect to Users’ rights and choices) unless otherwise stated when you provide it.
Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the categories of recipients or in connection with specific business purposes, each described below.
Service Providers and Contractors
In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other lawful business interests, we may share Personal Data with service providers, contractors, or subprocessors who provide certain services or process data on our behalf.
Your Personal Data may be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
In order to streamline certain business operations, share promotions and content we believe would be of interest to you, and develop products and services that better meet the interests and needs of our customers, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies.
In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of a Sales Contract, or in the vital interests of us or any person.
Note: These disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.
YOUR RIGHTS & CHOICES
Applicable law may grant you rights in your Personal Data. These rights vary based on your location, state/country of residence, and may be limited by or subject to our own rights in your Personal Data. You may contact us with respect to rights requests at firstname.lastname@example.org.
All rights requests we receive directly must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data. We may require that you log in to your account or verify that you have access to your account or the email on file in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.
For information regarding Californians Privacy Rights under the California Consumer Privacy Act (if you are a California resident), please see below.
Note: We are able to fulfil rights requests regarding Personal Data that we control or process. Please contact the Customer, or other appropriate third party directly to exercise your rights in information controlled by those parties.
You may have the following choices regarding the Personal Data we process, to the extent required under applicable law:
Consent: If you consent to processing, you may withdraw your consent at any time. You may be required to close your account in order to withdraw consent where your consent is necessary to perform essential aspects of our Services.
Direct Marketing: You have the choice to opt-out of or withdraw your consent to marketing communications. You may have a legal right not to receive such messages in certain circumstances, in which case, you will only receive direct marketing communications if you consent. You may exercise your choice via the links in our communications or by contacting us regarding direct marketing.
Other Processing: You may have the right under applicable law to object to our processing of your Personal Data for certain purposes, including without limitation, situations where we process in accordance with our business interests. You may do so by contacting us regarding data rights requests.
Note: We may not be required to cease processing based solely on your objection.
We implement and maintain reasonable security measures to safeguard the Personal Data you provide us. However, we sometimes share Personal Data with third parties as noted above, and though we may enter contracts to help ensure security, we do not control third parties’ security processes. We do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.
We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically, and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.
Our Services are neither directed at nor intended for use by individuals under the age of 18. Further, we do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete it.
We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Data may be transferred to the U.S. The U.S. may not provide the same legal protections guaranteed to Personal Data in foreign countries. Contact us for more information regarding transfers of data to the U.S.
Your California Privacy Rights
Under the California Consumer Privacy Act (“CCPA”) and other California laws, California residents may have the following rights, subject to your submission of an appropriately verified request (see below for verification requirements):
Right to Know
You may have the right to request any of following, for the 12-month period preceding your request: (1) the categories of Personal Data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the business or commercial purpose for which we collected or sold your Personal Data; (4) the categories of third parties to whom we have sold your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.
Right to Delete
You may have the right to delete certain Personal Data that we hold about you, subject to exceptions under applicable law.
Right to Non-Discrimination
You may have the right to not to receive discriminatory treatment as a result of your exercise of any rights conferred by the CCPA.
You may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes (if any) during the preceding calendar year.
Opt-Out of Sale
At this time, we do not sell Personal Data. If we engage in sales of Personal Data in the future (as defined by applicable law), you may direct us to stop selling or disclosing Personal Data to third parties for commercial purposes.
Submission of Rights Requests
You may submit rights requests to us at email@example.com. You may be required to provide additional verification information in order to complete your request, as described below.
Verification of Rights Requests
All rights requests must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data. We may require that you provide the email address we have on file for you (and verify that you can access that email account) and we may request additional information such as an address, phone number, or other data we have on file, in order to verify your identity. Depending on the sensitivity of the Personal Data you request and what type of request you submit, we may request additional information from you. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.
Supplemental Data Processing Disclosures
Categories of Personal Data Disclosed for Business Purposes
For purposes of the CCPA, we may disclose to Service Providers for “business purposes” the following categories of Personal Data: Identity Data, Contact Data, Device Data, Usage Data, Audio/Visual Data, and User Content.
For purposes of the CCPA, we do not “sell” your Personal Data.
Changes to Our Policy
We may change this Policy from time to time. Please visit this page regularly so that you are aware of our latest updates. Your use of the Services following notice of any changes indicates acceptance of any changes.
Feel free to contact us with questions or concerns using the appropriate address below.
General inquires: firstname.lastname@example.org
Privacy Rights & Compliance: email@example.com