Effective Date: July 31, 2023
WHAT WE COLLECT
We collect two types of information from Users who visit our Site, including:
- Non-personal information such as your IP address, device operating system, browser type used when accessing our site, language preferences, referring URLs, device name, country location and other website usage data. When using our site all personal information you provide to us must be true, complete and accurate and You must notify Us of any changes to such information.
- Personal information such as name, email address and telephone number. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.
HOW WE COLLECT IT
This information is collected in a number of ways depending on the page you are visiting, the activities you elect to participate in, or the services provided. You may be asked to provide information when you access a certain segment of the site, request information from us, access certain site features, opt in to receive additional information or engage in a purchase or enrollment transaction. We generally gather information in one of two ways including (1) automatically as you visit and navigate our site; and (2) directly from you, when you provide it to us by doing things such as filling in forms, registering for information, enrolling in trials, subscribing to our products or services, correspond with us or otherwise transact with us.
Like other trusted websites, we may collect information automatically through the use of tools that may be transparent to our visitors.
HOW IT’S USED
Your information is used in a variety of reasons, depending on how you interact with our services, including:
- To send you marketing and promotional communications. We may utilize the personal information you send to us for our marketing purposes, if this is in accordance with the marketing preferences you have selected or expressly opted in to. You can opt out of our marketing emails at any time.
- To deliver targeted advertising. We may use your information to develop and display personalized content and advertising tailored to your interests, location or other demographics.
- To protect our site and services. We may use your information as part of our effort to keep our site and services safe and secure including monitoring for and prevention of fraud.
- To identify usage trends. We may use information about how you engage with our Site and Services to better understand how they are being used as part of our effort for ongoing improvement.
- To determine the effectiveness of our marketing. We may use your information to better understand how to provide marketing that is most relevant to you.
- To save or protect vital interests. We may use your information when necessary to save or protect an individual’s vital interest.
We use personal information when we believe it to be necessary or when we have a valid legal reason to do so under law, such as with your consent, to comply with applicable laws, to provide you with services, to enter into or fulfill upon our contractual obligations, to protect your rights or to fulfill upon our legitimate business interests.
YOUR PRIVACY RIGHTS
In some regions you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability.
In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by sending an email to firstname.lastname@example.org. We will consider and act upon any request in accordance with applicable data protection laws. Specific regional and demographic policies are detailed below.
Withdrawing consent. If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by sending an email to email@example.com. Please note this will not affect the lawfulness of our utilization of your data prior to any withdrawal nor when applicable law allows.
Opting out of marketing and promotional communications. You can unsubscribe from any marketing or promotional communications at any time by clicking the unsubscribe link contained in any email received from us, or by submitting a written request to be removed from our marketing and promotional lists to firstname.lastname@example.org. Following receipt of such request, you will be removed, however, we may still communicate with you — for example, to send you service-related messages that are necessary for the fulfillment, access or use of your account, to respond to emails, tickets or other service or support requests, or for other non-marketing purposes.
REGIONAL AND DEMOGRAPHIC POLICIES AND INFORMATION
GENERAL DATA PROTECTION REGULATION (EEA or UK)
We also collect or obtain personal information from users in GDPR jurisdictions. This section of our statement is used to allow us to fulfill our EU GDPR obligations and explain your GDPR rights. For purposes of this section only, the words "you" and "your" refer expressly to GDPR jurisdiction based visitors and users.
- Consent. We may use your information if you have given us permission (consent) to do so for a specific purpose. Under the GDPR, you are entitled to the disclosure, access and deletion rights. You may be required to provide additional information, as to act on your request we must be able to verify your identity or your authority to make such a request, so in order for your request to be processed, you will need to follow our instructions for identity verification. You may exercise these rights annually by written request to email@example.com
- Legitimate Interests. We may use your information when we believe it I reasonably necessary to achieve our legitimate business interests and when those interests do not outweigh your interests, fundamental rights and freedoms. For example, we may use your personal information (1) to send users information about special offers on our products and services; or (2) to develop and display personalized and relevant advertising content for our users; or (3) to analyze how our services are being used in an effort to improve them to engage and retain users; or (4) to support our marketing efforts; or (5) to diagnose problems; or (6) to identify and prevent fraudulent activity.
- Legal Obligations. We may use your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may use your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
If the GDPR applies to you, you also have the right to contact your local data protection supervisory authority with questions, concerns or complaints and can find their contact details at: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
DATA PROTECTION REGULATION (SWITZERLAND)
We may collect or obtain personal information from users in Switzerland. For purposes of this section only, the words "you" and "your" refer expressly to Switzerland based visitors and users. If Switzerland’s data protection regulations apply to you, you have the right to contact your local data protection authorities with questions, concerns or complaints and can find their contact details at: https://www.edoeb.admin.ch/edoeb/en/home.html
DATA PROTECTION REGULATION (CANADA)
We also collect or obtain personal information from users in Canada. For purposes of this section only, the words "you" and "your" refer expressly to Canadian based visitors and users.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to use your information without your consent, including for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse or fraud
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or governing province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
CALIFORNIA CONSUMER PRIVACY ACT
When we collect personal information from California residents we become subject to, and those residents have rights under, the California Consumer Privacy Act ("CCPA"). This section of our statement is used to allow us to fulfill our CCPA obligations and explain your CCPA rights. For purposes of this section only, the words "you" and "your" refer expressly to California residents.
- What do we collect from California Residents? We collect the following categories of personal information: identifiers such as name, address, IP address, and other similar identifiers; personal information described in subdivision (e) of Section 1798.80 (California customer records statute) such as a name, address, telephone number, credit card number; commercial information such as products or services purchased; internet/electronic activity such as browsing history and search history; geolocation data including geographic coordinates/physical location; and audio, video, electronic or other similar information. We have disclosed these categories of personal information for business purposes within the last 12 months. We do not sell and have not sold this personal information to third parties.
- Rights of California Residents. Under the CCPA, you are entitled to the disclosure, access and deletion rights. You may be required to provide additional information, as to act on your request we must be able to verify your identity or your authority to make such a request, so in order for your request to be processed, you will need to follow our instructions for identity verification. You may exercise these rights annually by written request to firstname.lastname@example.org
VIRGINIA CONSUMER DATA PROTECTION ACT (CDPA)
When we collect personal information from Virginia residents we become subject to, and those residents have rights under, the Virginia Consumer Data Protection Act ("CDPA"). This section of our statement is used to allow us to fulfill our CDPA obligations and explain your CDPA rights. For purposes of this section only, the words "you" and "your" refer expressly to residents of the State/Commonwealth of Virginia.
"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context. "Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information. "Sale of personal data" means the exchange of personal data for monetary consideration. If this definition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
The information we collect, use, and disclose about you will vary depending on how you interact with the Site. Your rights with respect to your personal data:
- To be informed whether or not we are using your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you have shared with us
- Right to opt out of the use of your personal data if it is used for targeted advertising, sale of personal data or profiling of furtherance of decisions that product legal or similarly significant profiling events
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension. If we decline to take action regarding your request, we will inform you of our decision and reasoning. If you wish to appeal our decision, you may contact us by email at email@example.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
CHILDREN’S ONLINE PRIVACY AND PROTECTION ACT
Federal laws impose special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from, children under the age of 18. We take such restrictions seriously, and do not intend for our website or resources to be used by children under the age of 18. We do not knowingly collect personal information from minors under the age of 18. Should we become aware that anyone under the age of 18 has submitted personal information to our online and mobile resources without such parental or legal guardian’s consent, we will delete that information and will not use it for any purpose whatsoever. If you believe that someone under the age of 18 has submitted personal information through our website or resources, please contact us at firstname.lastname@example.org. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the internet.
WHEN AND HOW PERSONAL INFORMATION IS SHARED
We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to provide such services. We have contracts in place with our third parties which are designed to help safeguard your personal information. This means that (1) they cannot do anything with your personal information unless we have instructed them to do it; and (2) they will not share your personal information with any organization apart from us; and (3) they commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with may include, but are not limited to: ad networks, affiliate marketing programs, data analytics services, performance monitoring tools, sales or marketing tools, social networks, testing tools, website hosting providers.
We may also share your information (1) in connection with or during negotiations of a merger, sale of our company or company assets, financing or acquisition of all or a portion of our business; and (2) with our business partners to offer you products, services or promotions.
THIRD PARTY WEBSITES
Our site or services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link to a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the site or our services. You are responsible for reviewing the policies of such third parties or for contacting them directly with questions about their policies or practices.
COOKIES AND TRACKING TECHNOLOGIES
INTERNATIONAL TRANSFER OF INFORMATION
Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal, in the United States, and other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to store your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further use until deletion is possible.
HOW DO WE SAFEGUARD YOUR INFORMATION?
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we obtain. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we do our best to protect your personal information, transmission of personal information to and from our Site or while using our services is at your own risk. You should only access the Site and services within a secure environment.
CAN SPAM ACT OF 2003
We have taken the necessary steps to ensure that we are compliant with the CAN-SPAM Act of 2003 by never sending out misleading information. Visitors or Users shall not access or use (or direct or facilitate access or use of) our Site(s) or content in violation of the CAN-Spam Act of 2003, nor use our Site(s) or content to facilitate the dissemination of unsolicited bulk email in any way.
Users are encouraged to contact us with any questions or concerns via email at email@example.com