Effective Date: January 1st 2020
1 THE INFORMATION WE COLLECT.
We collect data to provide the products and services you request, ease your navigation on the Site, communicate with you, and improve your experience using the Site. Some of this information is provided by you directly to us, such as when you register for an account. Some of the information is collected through your interactions with the Site. We collect such usage data using technologies like Cookies, action tags, error reports, and other tracking technologies.
The data we collect depends on the products, services, and features of the Site that you use, and includes the following:
1.1 Personal Information.
When you visit the Site without creating an account, you can browse without submitting Personal Information about yourself. In general, we collect Personal Information that you submit to us in the process of creating or editing your account and user profile on the Site or that you submit to us voluntarily through your use of the Site. 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 is “Personal Information.”
A. Personal Identifiers.
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. Purchasing information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Photographs, videos, and audio files.
D. Financial Data
Bank account number, credit card number, debit card number, or any other financial information.
E. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F. Location or geolocation data.
Physical location or movements.
G. Professional or employment-related information.
Professional or employment-related information, union memberships, current or past job history or performance evaluations.
H. Data about others.
Other people’s contact information to send invitations or gifts or to share content.
· Publicly available information from government records.
· De-identified or aggregated consumer information.
We may also collect Personal Information from third parties, such as, Payment Processors, product vendors, and other partners. Our collection of this information allows us to provide you with our products and services, establish, maintain and support your user account on the Site, and communicate with you in accordance with our Terms.
1.2 Automatically Collected Usage and Device Information.
Similar to other websites, we use tracking technologies to automatically collect certain technical information from your web browser, mobile, or other device when you visit our Site. This data may include, without limitation, your IP address, browser type and language, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time of your visits. Our collection of this data, described in more detail below, allows us to provide more personalized services to you and to track usage of the Site.
We automatically derive and collect certain data based on your interactions with the Site using cookies and similar technologies (collectively, “Cookies”). Our collection of data through Cookies includes information about your browser and Site usage patterns, which may include your IP address, browser type, browser language, referring/exit pages and URLs, pages viewed, links clicked, whether you opened an email, and information about the device you use to access the Site. Our collection of this information allows us to improve your user experience in various ways, such as to personalize our display of the Site to you, to “remember” whether or not you are signed in, and to provide better technical support to you.
Please note: If you restrict, disable, or block any or all Cookies from your web browser or mobile or other device, the Site may not operate properly, and you may not have access to certain services or parts of the Site. We will not be liable for any interruption in, or inability to use, the Site or our services or degraded functioning thereof, where such are caused by your settings and choices regarding Cookies.
B. Pixels (aka web beacons/web bugs/java script).
We may use Pixels to automatically record certain technical information about your interactions when you visit the Site or otherwise engage with us, to help deliver Cookies on our Site, or count users who have visited the Site. We may also include web beacons in our promotional e-mail messages or newsletters to determine whether you open or act on them for statistical purposes. “Pixels” are tiny graphics (about the size of a period at the end of a sentence) with unique identifiers used to track certain online actions, movements and related information of Site users. Unlike Cookies, which are stored on a user’s computer hard drive, Pixels are embedded invisibly on web pages or in HTML-based emails. The data we receive through Pixels allows us to effectively promote the Site to various populations of users, and to optimize external advertisements about the Site that appear on third-party websites.
1.3 Information from Other Sources.
We may obtain both personal and non-personal information about you from business partners, contractors, suppliers, and other third parties and add it to your account information or other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across the Site, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.
1.4 Location Information.
We collect your address information, e.g., shipping and billing address, when you set up your account and order our products or services. We also collect and use information about your general location (e.g., your state of residence) and can infer your approximate location based on your IP address in order to track our general Site usage or to tailor any pertinent aspects of your user experience to the region where you are located.
1.5 Information about Others.
3 EXTERNAL LINKS.
4 HOW WE USE YOUR INFORMATION.
We may use or disclose the Personal Information identified above for one or more of the following business purposes (“Business Purpose”):
· To fulfill or meet the reason you provided the information (e.g., to help provide products and services to you);
· To personalize and develop our Site and the services we provide you through the Site and improve our offerings;
· To provide certain features or functionalities on the Site;
· For marketing and promotions;
· To create, maintain, customize, and secure your account with us;
· To provide you with support, to communicate with you and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
· To personalize your experience and to deliver content and product and service offerings, products, and services relevant to your interests, including offers and advertisements through third-party sites, and via email (with your consent, where required by law);
· To help maintain the safety, security, and integrity of our Site, services, databases, other technology assets, and business;
· For testing, research, analysis, and product development, including to develop and improve our Site and services;
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
· To prevent illegal activity, fraud, and abuse; or
· 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 users is among the assets transferred or liquidated.
4.2 Account-Related Emails.
When you create an account with us and provide us with your email address we may, subject to applicable law, use your email address to send you Site-related notices (including any notices required by law, in lieu of communication by postal mail), updates, news, and marketing messages. For example, when you register for an account, you will receive a welcome email. If the Site or our services are temporarily unavailable, we may also send you an email notice.
Email communications you receive from us will generally provide an unsubscribe link or instructions allowing you to opt out of receiving future emails or to change your contact preferences. If you have an account with us, you can also change your contact preferences by updating your contact information within your account settings. Please remember that even if you opt out of receiving marketing e-mails, we may still send you important service information related to your account and the Site. If you correspond with us by email, we may retain the content of your email messages, your email address, and our responses.
4.4 Non-Personally Identifiable Information.
We may use non-personally identifiable information, such as anonymized and/or aggregated Site usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the Site, including to develop new features, functionality, and services, to conduct internal research, to better understand Site usage patterns, to resolve disputes, to troubleshoot problems, to fulfill user requests, or for security and compliance purposes. Any non-personally identifiable information that is combined with Personal Information will be treated by us as Personal Information.
4.5 Payment Processors.
If you purchase or pay for products or services via the Site, the transaction may be handled by our service providers or third party vendor(s) responsible for processing your payment (“Payment Processors”). These entities have their own privacy policies and those terms will apply to you. Please be sure to review them at the links provided during payment processing.
5 OUR INFORMATION SHARING PRACTICES.
When we disclose Personal Information for a Business Purpose, we work with our partners to ensure that your Personal Information is protected in accordance with applicable laws. We share your information, including any Personal Information, in the circumstances described below.
5.1 Legal Requirements.
We reserve the right to disclose all information collected via the Site, internally, to affiliates, or to third parties, for any lawful purpose or to prevent harm to us or others. For example, and without limitation, in our discretion we may disclose information to government regulators, law enforcement authorities or alleged victims of identity theft. We will notify you in the event of a government or legal request for your information unless otherwise prohibited by law.
5.2 Organizational Transitions.
6.1 You Can Choose Not to Provide Personal Information.
You may always decline to provide your Personal Information to us. Registering for an account or otherwise providing your Personal Information is not required to access some of our online content. If you choose not to provide certain Personal Information to us, some of your experiences may be affected.
6.2 You May Decline Other Requests.
6.3 Right to Access Specific Information and Data Portability Right.
In some jurisdictions, you have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
If you reside within the European Union, you have the right to ask for a copy of your personal data and/or ask for it to be ported to another provider of your choice. Please note that such a request could be limited to the only personal data you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures.
6.4 Right to Correct and Delete.
In some jurisdictions, you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data is required to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the applicable law.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) or vendor(s) to:
· 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;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
· 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;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
· Comply with a legal obligation or legal order; or
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
6.5 Exercising Your Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us an e-mail at email@example.com.
You may only make such a request for access or data portability twice within a twelve-month period. 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, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
6.6 Online Tracking Choices.
Most browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, some features and services of the Site (particularly those that require sign-in) may not function properly if your Cookies are disabled. Similarly, if you choose to delete session objects from our Site, you may not be able to access and use all or part of the site or benefit from some or all of the information or features and services offered.
Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have the user’s online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about that browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many websites, including the Site, do not respond to DNT signals.
7 SAFETY AND INFORMATION SECURITY MEASURES.
We use certain physical, managerial, and technical safeguards designed to preserve the security of your information that we maintain in connection with your use of the Site. This, however, does not guarantee that your information may not be accessed, disclosed, altered, or destroyed by any breach of our physical, technical or managerial safeguards. In the event that any of your Personal Information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and will notify you, as appropriate, in accordance with pertinent laws and regulations.
We or our third party hosting providers store Personal Information in operating environments that are safeguarded against public or unauthorized access and protected from internal access with physical and technical security measures. While these measures are helpful to safeguard your Personal Information after we receive it, no transmission of data over the internet is 100% secure.
8 NOTICE TO USERS OUTSIDE THE UNITED STATES.
Please be aware that we are headquartered in the United States. The Site is governed by United States law. If you are using any of our products or services from outside of the United States, your information may be transferred to, stored, and processed in the United States where our servers may be located. The United States might not offer the same level of privacy protection as the country where you reside or are a citizen. BY USING THE SITE, COMMUNICATING WITH US VIA MAIL, EMAIL OR TELEPHONE, OR OTHERWISE PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO, AND PROCESSING OF, YOUR INFORMATION IN THE UNITED STATES.
9 CHILDREN’S PRIVACY
You must be at least the age of majority in your place of residence to use the Site. The Site is not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to inform the child (or his or her parent or legal guardian) that he or she cannot use the Site.
10 THE GENERAL DATA PROTECTION REGULATION (GDPR).
Residents of the European Economic Area (“EEA”) may be entitled to rights under the GDPR. If you qualify, these rights are summarized below.
If you request to exercise your rights under the GDPR, we may require verification of your identity before we respond to any such request. If you are entitled to these rights, you may exercise the following rights with respect to your Personal Information that we collect and store:
· the right to withdraw consent to data processing at any time;
· the right of access to your Personal Information;
· the right to request a copy of your Personal Information;
· the right to correct any inaccuracies in your Personal Information;
· the right to erase your Personal Information;
· the right to data portability, meaning to request a transfer of your Personal Information from us to any other person or entity as chosen by you;
· the right to request restriction of the processing of your Personal Information; and
· the right to object to processing of your Personal Information.
You may exercise these rights free of charge. These rights will be exercisable subject to limitations as provided for by the GDPR. Any requests to exercise the above-listed rights may be made to: firstname.lastname@example.org. If you are an EEA resident, you have the right to lodge a complaint with a Data Protection Authority about how we process your Personal Information at the following website: https://edpb.europa.eu/about-edpb/board/members_en.
12 CONTACT INFORMATION.