Last Updated June 1, 2022
If you choose to visit and use our Sites, your visit and any dispute over privacy is subject to this Policy and our User Agreement and Terms & Conditions, including limitations on damages, resolution of disputes, and application of the law of the state of Delaware.
This policy applies to information we collect on the Sites, in email, text, and other messages between you and the Sites, and when you interact with our advertising and applications on third-party websites and services (if those applications or advertising include links to this policy).
We may collect your information in a variety of ways through your use of the Site. This includes your visit to and browsing through the Sites and their pages, your filling out and submitting a form or email address, or access and use our Sites. The type of information we collect varies and may include:
1. Personal Information you voluntarily provide to us.
We collect information that identifies an individual (“Personal Information”). This would include first name, last name, personal address, phone number, email address, your location information, certain Usage Data (defined below), such as IP address (but see the explanation about IP address as explained in the Usage Data below.
Our Sites obtain information directly or indirectly from you. For example, we can directly collect information from forms you complete or products and services you purchase. This includes information provided at the time of subscribing to our service, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Sites. Records and copies of your correspondence (including email addresses), if you contact us. We can also indirectly collect information from observing your actions on our Sites or our products or services. Additionally, we collect Personal Information from a number of sources, such as from publicly available sources.
2. Non-personal Information we collect when you access or use our Sites.
Non-personal information is information that does not necessarily identify you as an individual (“Non-personal Information”). This may include a variety of information, including, but not limited to, Usage Information (defined below) and information related to your interaction with our Sites.
“Usage Information” or “Usage Data”—information about an individual’s online activity that, by itself, does not identify the individual, such as: your activity in using our Sites (for example, terms you search for, videos you watch, your views and interactions with content and ads, purchase activity, people with whom you communicate or share content, and activity on third-party sites and apps that use our services), technical information, including your browser type, service provider, IP address (IP address, by itself, may or may not identify your as an individual under the applicable laws and therefore this type of information may also be listed under Subsection 1 “Personal information you voluntarily provide to us” above or as described on the separate page applicable only to California residents under the California Consumer Privacy Act), operating system and web pages visited; information about what you’ve searched for and looked at while using the Sites and services or how you interact with the Sites; metadata, which means information related to items you made available through the Sites, such as the date, time or location that a shared photograph or video was taken or posted. We and our third-party partners may use various technologies to collect and store Usage Data in connection with our Sites. These may include things like cookies, other similar technologies or data collection tools (such as pixels, web beacons and server logs), which we collectively refer to as “data collection tools.”
Generally, we do not consider Usage Data as Personal Information because Usage Data by itself does not usually identify an individual. Personal Information and Usage Data, as well as different types of Usage Information, may be linked together and, once linked, may identify an individual person. Some Usage Data may be Personal Information under applicable law and will be treated as such. If we do combine Non-personal Information with Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
We collect information about you in the following ways:
● When you voluntarily provide your information to us in order to use our Sites. For example, we collect Personal Information from you when you call/email or contact us for help or otherwise voluntarily provide your Personal Information.
● When you complete a client satisfaction, a review, or market research survey.
● When you download or use apps created by us or our subsidiaries, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to turn off location services.
● To help us make emails more useful and interesting, we often receive a confirmation when you open an email from us if your computer supports such capabilities. We also compare our customer list to lists received from other companies, in an effort to avoid sending unnecessary messages to our customers. If you do not want to receive email or other mail from us, please email us at firstname.lastname@example.org or adjust your communication preferences at Privacy Data Request Form.
● We use analytics services (such as Google, SendInBlue and Amplitude Analytics) to collect and analyze usage information through cookies and similar tools to engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web pages.
We may collect, process, use or disclose your Personal Information for the following purposes:
● To provide to you any services offered or will be offered on the Sites
● To process your requests, purchases, transactions, and payments and prevent transactional fraud.
● To help maintain the safety, security, and integrity of our Sites, products and services, databases and other technology assets, and business.
● To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
● We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any information (including Personal Information) as reasonably necessary to comply with any applicable law, regulation, subpoena or legal process, or respond to any governmental requests and cooperate with law enforcement, if we believe such action is required or permitted by law.
● Where you have given consent.
● As otherwise permitted or required by applicable law.
● To design and improve our Sites and our content and to enhance your overall Sites experience.
● To help provide technical and services support and client/user communications.
● To design and improve our Sites and our content and to enhance your overall Sites experience.
● To respond to your requests, verify your identity, and carry out requests made by you on the Sites or in relation to our services.
● To protect the rights, property or safety of us or third parties, including our other clients and users of the Sites.
● To maintain our records, to provide notification to users about updates, Sites, and changes to our terms, conditions, and policies and to respond to your requests, verify your identity, and to carry out requests made by you on the Sites or in relation to our services.
● To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
● As described to you when collecting your personal information or as otherwise set forth in the California Consumer Privacy Act.
● To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Sites is among the assets transferred.
● To create your account and provide the services to you. We use the information we collect to create and secure your account, create and maintain your Member Profile, and to provide the services to you.
● To communicate with you. We use information we collect to provide you with support or to send you things like service-related announcements.
● To conduct research and to improve and promote our services. We use the information we collect to conduct research and to improve or enhance and promote our Sites.
● To enforce our Terms of Service, including investigating any potential violations.
● To conduct market research, implement marketing strategies, identify potential business opportunities, and administer any promotional programs by sending you email marketing communications about our products and services, newsletters, and promotions.
● To create, maintain, customize, and secure your account with us, including to investigate and address your concerns and monitor and improve our responses.
● For testing, research, analysis, and product development, including to develop and improve our Sites, products, and services.
We share and publish Personal Information we collect with certain third parties, as we deem necessary, with your consent, or as we see appropriate in connection with delivering, operating, maintaining and/or providing the Sites to you. We may also share your personal data with third parties when you intentionally direct us to do so or when you use our Products or Services to intentionally interact with third parties.
● Our professional advisers, such as lawyers and accountants.
● Law enforcement and public and governmental authorities as it may be necessary by law, legal process, litigation, and/or requests whether they come within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. This also applies to Non-personal Information.
● Other third parties if we determine that disclosure is reasonably necessary to enforce our terms and conditions, to fulfill legal duties and avoid conflicts of interest, to protect our operations or clients, as well as our rights, property, or interests, or to prevent misuse or unauthorized use of the Sites.
● Other third parties when you have agreed that we may do so.
● Other companies and individuals to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes.
● Third parties we use to build our Sites and maintain our Sites, to assist us with client insight analytics, and to provide data hosting, software, cloud services to store your information, or other technology services. We will share your Personal Information only as necessary for the third parties to provide those services. Additionally, if we use or partner with third parties to provide specific services or information to you, those third parties may be allowed to use your Personal Information to provide such services.
● Our parent company may use your data for purposes of tracking sales; contacting current and potential customers in connection with marketing our company and other of our parent company’s products and services; assisting current and potential customers; and for internal business purposes, such as conducting research and analysis in order to improve our products and services.
● We do not share your Personal Information with third parties for their direct marketing purposes.
● Unless otherwise described in this policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes and may only share it with third parties described above.
● We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales.
● The information you provide may also be provided to our partners and third parties we believe may offer products or services of interest to you. [We screen all third parties that would receive such information and reviews the intended use of the data before providing any information to them. These parties include such companies as software and hardware vendors and other information providers].
We offer you the opportunity to opt out of receiving promotional e-mail, calls or mail from us about our products and services. Please contact us using the contact information provided at the end of this Policy. [For e-mail, individuals may opt out at any time by using the unsubscribe mechanism within the e-mail, which allows individuals to manage their subscription preferences regarding our newsletters, e-mail alerts and special offers.] This mechanism does not allow a user to opt out of receiving transactional e-mail, such as registration confirmation, product updates and responses to direct requests.
We may collect, use, transfer, and disclose Non-personal Information for any purpose, in any manner, and to any third party as we deem appropriate or necessary. We may also sell Non-personal Information from time to time at our sole discretion.
Our Sites are not directed at children or users under the age of 13. If we learn that we have collected the Personal Information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
The services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Data through the services.
We recognize the need to provide further privacy protections with respect to personal information we may collect from children on our sites and applications. Some of the features on our sites and applications are age-gated so that they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:
● Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information.
● In accordance with applicable law, and our practices, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children
● Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity.
● Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.
Our Sites and service is intended only for access and use by individuals at least eighteen (18) years old. By accessing or using Service, you warrant and represent that you are at least eighteen (18) years of age and with the full authority, right, and capacity to enter into this agreement and abide by all of our terms and conditions governing our Sites and service. If you are not at least eighteen (18) years old, you are prohibited from both the access and usage of our Sites and/or Service.
We do not respond to or take any action with respect to a DNT configuration set in your internet browser, and therefore, do not disable tracking.
The Personal Information we collect is stored in one or more databases hosted by one or more third parties. We require companies performing services on our behalf to protect your Personal Information in a manner appropriate to the type and sensitivity of the information, and to use it only in connection with those services.
We may retain and use Non-personal Information for as long as needed and as we deem appropriate and necessary for any purposes, including but not limited to, to develop, improve, and provide services, comply with our legal obligations, resolve disputes, perform fraud prevention efforts, and enforce our agreements.
To help protect the privacy of Personal Information you transmit through use of our Sites, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your Personal Information to our employees, independent contractors, and our third-party vendors who need to know that information to provide benefits or services to you. When you provide your payment information to us, this information is stored on our third-party provider’s secure servers. Our third-party provider uses encryption technology to ensure safeguards are in place. We have appropriate security measures to prevent Personal Information from being accidentally lost, or used or accessed unlawfully.
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.
We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, security system, or method of electronic storage, is 100% secure. Although we do our best to protect your Personal Information, we do not guarantee the security of any information you transmit to us or provide online. Any transmission of Personal Information is at your own risk. If you have any questions about security on our Sites or services, you can contact email@example.com.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) access to certain parts of our Sites, you are responsible for keeping this access confidential. We ask you not to share this access with anyone. We urge you to be careful about giving out personal or private information in public areas of the Sites. The information you share in public areas may be viewed by any user of the Sites.
If you are a California resident, you may be entitled to additional rights over your personal information. For more information about those rights and how to exercise them, please see our California privacy notice here, which is incorporated by reference into this policy.
You may request us to have access, correct, amend, update, or delete your Personal Information, or update your preferences, including opting out of particular communications, by contacting [email]. Please remember that limited communications may be necessary in order to complete your transaction or for you to participate in our Services.
We collect information that information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“California Personal Information”). We have collected the following categories of California Personal Information within the last 12 months:
A real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Categories of Personal Information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other Personal Information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The following are the business purposes for which we may use your information include:
● Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf.
● Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same.
● Debugging to identify and repair errors in our systems.
● Short-term, transient use including contextual customization of ads.
● Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services.
● Conducting internal research to develop and demonstrate technology. and
● Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide.
We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.
If you are a California resident, you have certain rights related to your California Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law.
● You have the right to request that we disclose to you the specific species of personal information we have collected.
● You have the right to request that we delete California Personal Information about you which we have collected from you.
You may request that we disclose to you:
● the categories of California Personal Information we have collected about you.
● the categories of sources from which the California Personal Information is collected.
● our business or commercial purpose for collecting or selling California Personal Information.
● the categories of third parties with whom we share California Personal Information.
● the specific pieces of information we have collected about you.
To the extent that we sell your California Personal Information within the meaning of the California Consumer Privacy Act or disclose such information for a business purpose, you may request that we disclose to you:
● the categories of California Personal Information that we have collected about you.
● the categories of California Personal Information about you that we have sold within the meaning of the California Consumer Privacy Act and the categories of third parties to whom the California Personal Information was sold, by category or categories of personal information for each third party to whom the California personal information was sold.
● the categories of California Personal Information about you that we disclosed for a business purpose.
In addition, we may sell your information within the meaning of the CCPA. You have the right to opt out of such sales here. To submit an opt-out request, click the Do Not Sell My Personal Information link.
You may also request to exercise these rights by:
● By requesting our rights request form available here firstname.lastname@example.org
● Calling us toll-free at 1 888 673 82 20.
As required or permitted under applicable law, please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may limit our response to your exercise of the above rights as permitted under applicable law. Subject to applicable law, we may not discriminate against you because of your exercise of any of the above rights, or any other rights under the CCPA, including by:
● Denying you goods or services;
● Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
● Providing you a different level or quality of goods or services; or
● Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
If you are a California resident, you have the right to opt out of our sales of certain information relating to individuals and households subject to the California Consumer Privacy Act. To exercise this opt-out right, whether you have an account or not, please submit a request via [email]. If you do not have an account, include your name and email address or mailing address.
Phone: 1 888 673 82 20
Wilmington DE 19807-2039 USA