- Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
- Explain the way we use the personal data that you share with us in order to give you a great experience when you are using any of our capabilities, software or services that may be made available through the Web Site; and
- Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
We hope this helps you to understand our privacy commitments to you.
2. Personal Information
3. What Personal Information Do We Collect?
Personal Information is collected as part of the application and registration process on the Web Site for user account provisioning if you choose to provide such Personal Information to us. Such information includes, but is not limited to, family name, given name, address, email, and phone number.
Additionally, we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs (“Web Site Usage Information”).
4. User-Provided Personal Information
We also collect Personal Information from persons access or use any capability, software or service that may be made available through the Web Site, through such users’ activities, submission of information or materials or completion of online forms on the Web Site and/or registration for use of or access or use of any such capability, software or service, including, for example, when users submit information or materials on or through the Web Site or such other capability, software or service, send us an e-mail, or in any other way submit Personal Information to us via the Web Site.
5. How is the Personal Information used?
We may use your Personal Information:
- to provide the Services and to operate, maintain or improve the Web Site, any capability, software or service that may be made available through the Web Site or our business;
- to respond to your requests or inquiries;
- to support auditing, legal or compliance functions;
- to contact you, including to request your feedback on any of our capabilities, software or services;
- to keep our capabilities, software and services safe and secure (for example, for fraud monitoring and prevention);
- to manage your account; and/or
- to maintain our internal record keeping.
We may also link this information with other information that you provide to us or that we obtain from other sources and Web Site Usage Information (as defined below). We may analyze user behavior as a measure of interest in, and use of, the Web Site and/or any capability, software or service that may be made available through the Web Site and e-mails, both on an individual basis and in the aggregate.
6. Do we share Personal Information and Web Site Usage information with others?
We may process or share your data that we hold based on the following basis:
- Consent: We may process your data if you have given us specific consent to use your Personal Information for a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your Personal Information to fulfill the terms of our contract.
- Legal Compelled Disclosure: We may disclose Personal Information to government authorities, and to other third parties when compelled to do so by government authorities or regulators, at our discretion, or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas, regulator requests or to enforce our legal rights or agreements with you or others. We also may disclose Personal Information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Web Site, or anyone else that could be harmed by such activities.
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
We have not disclosed or sold any Personal Information to third parties for a business or commercial purpose in the preceding 12 months.
7. Service Providers
We may use third-party partners to help operate the Web Site and/or any capability, software or service that may be made available through the Web Site, and, as discussed above, may share your information with our affiliates and related entities, service providers and other third parties that provide products or services for or through the Web Site and/or any capability, software or service that may be made available through the Web Site or for our business (such as Web site or database hosting companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfillment companies, and other similar service providers that use such information on our behalf).
8. Cookies and Related Technologies and Web Site Usage Information
When you use the Web Site and/or any capability, software or service that may be made available through the Web Site, we collect Web Site Usage Information. As you use the Web Site and/or any such capability, software or service, your browser and devices communicate with servers operated by us and services providers to coordinate and record the interactivity and fill your requests for services and information. The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to us by your computers or mobile devices. These servers are operated, and the cookies managed by us, our business partners or our service providers. For example, when you access the Web Site and/or any such capability, software or service, we and our service providers may place cookies on your computers or mobile devices. Cookies allow us to recognize you when you return so you will not be required to register again for use of the same and track your use of the Web Site and/or any such capability, software or service. They also help us to detect certain kinds of fraud. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your registration and your use of the Web Site and/or any such capability, software or service. Some cookies contain numbers that allow us to connect the Web Site and/or any such capability, software or service activity with other information we store about you in your profile or as related to your interactions with the Web Site and/or any such capability, software or service. Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided and storing such information.
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us or our service providers. These tools allow us to measure response to our communications and improve the Web Site and/or any such capability, software or service.
We collect many different types of Web Site Usage Information. For example, we may collect information from the devices you use to access the Web Site and/or any capability, software or service that may be made available through the Web Site, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the Internet Protocol (“IP”) addresses of the devices you use to interact with the Web Site and/or any such capability, software or service. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet.
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our capabilities, software or services.
9. Aggregate Statistics
We may disclose aggregate statistics regarding user behavior as a measure of interest in, and use of, the Web Site and e-mails to third parties in the form of aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user.
While we will endeavor to take commercially reasonable steps to protect the security and integrity of Personal Information provided to us, we cannot guarantee that any information will be absolutely safe from intrusion by others, such as hackers, during transmission through the Internet or while stored on our system or otherwise in our care.
If you contact us by e-mail or a “contact us” or similar feature on the Web Site and/or any capability, software or service that may be made available through the Web Site, you should be aware that your transmission might not be secure. A third party could view information you send by these methods in transit. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.
In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification.
11. Consent to Worldwide Transfer and Processing of Personal Data
12. Privacy Policies of Third-Party Websites
13. Length of Time Personal Information is Retained
14. Controls for Do-Not-Track Features
15. California Specific Provisions
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by sending an email to email@example.com.
If you are under 18 years of age, reside in California, and have a registered account with us, you have the right to request removal of unwanted data that you publicly post on our services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed by us, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
Your Rights Under the CCPA.
California consumers have certain rights under the California Consumer Privacy Act of 2018 (CCPA) and other privacy and data protection laws regarding their personal information.
Disclosure of Personal Information We Collect About You. You have the right to know:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting or selling personal information;
- The categories of third parties with whom we share personal information, if any; and
- The specific pieces of personal information we have collected about you.
- Please note that we are not required to:
- Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Right to Deletion. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will delete your personal information from our records; and direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination. You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. Unless otherwise permitted by the CCPA, this means we cannot, deny goods or services to you; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Minors under the age of 18 may not use the Web Site. We do not collect or maintain information from anyone known to be under the age of 13, and no part of the Web Site is designed to attract anyone under the age of 13.
If you have any questions or comments regarding our privacy practices, you may contact us at firstname.lastname@example.org
Effective since: October 1, 2022