Last Updated and Effective as of: December 20, 2022
• We collect Personal Information (as defined below) from users of our Website and Services when it is voluntarily provided to us and use it for the purposes for which it was provided (see Information We Collect Directly From You and How We Use Your Information).
• We automatically collect information (which may include Personal Information) from users of our Website and Services for advertising and analytical purposes and in order to provide the Services (see Information We Collect Automatically and How We Use Your Information).
• We may obtain Service Data from our clients and their vendors, which we process on behalf of our clients in accordance with our contracts with them.
Our Website and Services are provided from the United States and all servers that make it available reside in the United States. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. The Website and Services are intended for users situated in the United States.
If you have questions, you can always contact us using the information in the section below titled Contact.
- INFORMATION WE COLLECT DIRECTLY FROM YOU
We may collect information, including Personal Information, when you provide such information to us directly, such as when you send us an email, or otherwise interact with us on the Website or in connection with the Services. Your provision of your Personal Information to us this way is completely voluntary. “Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Such information may also be referred to as “personal data” or “personally identifiable information” under applicable laws, which may provide their own definitions.
Categories of Personal Information we may collect directly from you on the Website and Services include: identity data (e.g., name or other identifiers); and contact data (e.g., email address or telephone number). We may also collect other information that you directly provide us, including marketing and communications data (e.g., your preferences in receiving marketing from us).
- INFORMATION WE COLLECT AUTOMATICALLY
We, our service providers or our third party partners may also automatically collect information, including Personal Information, from you when you visit our Website and use or interact with our Services through cookies and other tracking technologies. While some of this information (like a device ID or cookie ID) does not enable us to directly identify you or other users (e.g., we do not know your name or contact information), that information may still be considered Personal Information under applicable privacy laws. Such information may include data collected by the following methods:
- Cookies and Similar Technology
- Clickstream Data
As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Website or interacted with our Services. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Website (or other Services), how visitors navigate throughout the Website and Services and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Website and our Services.
- Site and Platform Analytics
- HOW WE USE YOUR INFORMATION
We may use Personal Information and other information as described herein including for the following purposes:
- To contact you about and provide you and our clients with our services;
- To operate the Website and Services, and to provide you with any specific services that you have requested;
- To deliver content and product and service offerings relevant to your interests;
- To identify trends and make inferences about you and your interactions with us or our affiliates or our business partners, such as to analyze your behavior and preferences, and to evaluate and improve the products and services of our affiliates and business partners;
- To market Company goods and services or goods and services of those of our affiliates, business partners, and other third parties;
- To provide you advertising for products and services that may be of interest to you;
- To respond to law enforcement requests and as required by applicable law, court order, legal process, or governmental regulation;
- To help maintain the safety, security, and integrity of our Website and Services, databases and other technology assets, and business;
- For internal research; for technological development and demonstration; and to improve, upgrade, or enhance our Website and Services;
- For detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity;
- To investigate suspected fraud, harassment, or other violations of any law, rule, or regulation, or the policies for the Website and Services;
- In connection with a bankruptcy proceeding or the sale, merger, or change of control of the Company or the division responsible for the services with which your information is associated;
- To respond to your direct inquiries;
- To add you to our mailing lists and send you emails from time to time; and
- For any additional purposes that you specifically consent to.
As noted above, we may collect information that is not Personal Information (“Non-Personal Information”), including information lawfully made available from federal, state, or local government records, or aggregate or de-identified information. Because Non-Personal Information does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine Non-Personal Information with Personal Information. If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information.
- HOW WE SHARE YOUR INFORMATION
- Service Providers/Vendors. We may share your Personal Information with third parties who may use your information to provide us services such as website hosting, data analysis, infrastructure provision, information technology services, customer service, email delivery services, auditing, and anti-fraud monitoring. These third parties may have access to Personal Information that is necessary to perform their functions.
- Legal Compliance and to Defend Our Rights. We may disclose Personal Information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- Business Transfers. We may share your Personal Information and other information with third parties in connection with a corporate restructuring, acquisition, or divestiture.
- Aggregated or Non-Personal Information. We may share aggregated information or Non-Personal Information with unaffiliated third parties, such as business partners, manufacturers, distributors, and retailers for a number of purposes, including for purposes of improving and enhancing your experience using the Website and Services, and for our market research activities.
Please note that if you specifically consent to additional uses of your Personal Information, we may use your Personal Information in a manner consistent with that consent.
- INTEREST-BASED ADVERTISING
We may use information we collect (alone or in combination with information provided by third parties and service providers) to deliver targeted advertising (about Company or other third party products and services) to you when you visit our Website and Services or other websites. Information about you may be used in this process. For example, if you are searching for information on a particular product, we may use that information to cause an advertisement to appear on other websites you view with information on that product. We may, now or in the future, have the ability to engage in “cross-device matching” to display targeted advertisements to you across browsers and devices (as described in Section 5 above).
To further clarify, we partner with third parties that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you or your business. Our partners may place or recognize a cookie on your computer, device, or directly in our emails/communications, and we may share Personal Information with them if you have submitted such information to us, such as your name, postal address, email address, or device ID. Our partners use this information to recognize you across different channels and platforms, including but not limited to, computers, mobile devices, and Smart TVs, over time for advertising, analytics, attribution, and reporting purposes.
If you would like to opt-out of these interest-based advertisements or “cross-device matching,” please see Your Choices, below.
The security of your information is very important to us. We attempt to provide for the secure transmission of your information from your devices to our servers by utilizing Secure Sockets Layer (“SSL”) encryption, when reasonably available. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and the Company, or information stored on the Website and Services or our servers, will be free from unauthorized access by third parties such as hackers, and your use of the Website and Services demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Information. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us firstname.lastname@example.org.
- DATA RETENTION
We will retain your information for as long as your inquiry is active or as needed to provide you with the Website and Services, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregated data previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.
- PROTECTION FOR CHILDREN
Our Website and Services are intended for users ages 18 and over. We do not knowingly collect Personal Information from minors. When we become aware that Personal Information (or other information that is protected under applicable law) from a child under 13 has been collected, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any Personal Information from or about a child under 13, please contact us at email@example.com.
- YOUR CHOICES
We strive to offer you with choices about how information is used and shared. There are several ways in which you may opt out of the various programs and services we provide. Some of the ways in which you may opt out are described below.
Opting Out of Our Services. If you receive a marketing email from us, you may unsubscribe from future marketing emails in accordance with our standard unsubscribe process, or by sending an unsubscribe request to us at firstname.lastname@example.org. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of our services may no longer be available to you.
- NEVADA PRIVACY RIGHTS
If you are a Nevada resident, you have the right to request that we do not sell your covered information (as those terms are defined in N.R.S. 603A) that we have collected, or may collect, from you. We do not sell your covered information, however, if you would like to make such a request you may do so by contacting us at email@example.com.
- YOUR CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act of 2018 (“CCPA”), amended by the California Privacy Rights Act of 2020, provides you with specific rights regarding your Personal Information. In order to provide our Services to our clients, we may process Service Data that we receive from or on behalf of our clients. If you are a California resident, you may have certain CCPA rights pertaining to such information. Under the CCPA, when we act as a “service provider” (not as a “business” or a “third party”) over such information, we only process your information through our Services as necessary to provide our services to our clients, at our clients’ direction. If you wish to exercise any of your rights under CCPA in regards to such information, please contact the relevant business that collected the information from you, who controls and determines how your information is processed.
Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at firstname.lastname@example.org. If you do not want your personal information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at email@example.com.
- CHANGES TO POLICY
For questions or concerns relating to privacy, we can be contacted at: firstname.lastname@example.org or at 888.525.4121.