We kindly ask that you read this Policy carefully so that you may understand our practices concerning your information and how we will treat it. After reading this Policy, if you do not agree with it, DO NOT proceed to use, access, or visit the Website. By using, accessing, or visiting the Website, you indicate your agreement with and acceptance of this Policy. We last updated this Policy on December 17, 2019. We may change this Policy from time to time without notice to you; accordingly, you should check this Policy regularly for any such updates. Your continued use of or access to the Website after any such changes are made indicates your agreement to and acceptance of them.
As a preliminary matter, we have implemented the appropriate technical and organizational measures to maintain a level of appropriate security for the information that you provide to us. Moreover, we only allow the individuals who need access to the information to have access to it, and we will not process it unless allowed by the applicable law.
How We Collect Information From You
We may collect information from you in several ways. We may collect information from you when you knowingly give it to us. For example, you may knowingly give us your information when you complete and submit forms on our Website (such as our “Contact Us” page), or when you register with our Website, enter a contest or promotion on our Website, report a problem with our Website, or email or otherwise message us via the Website. By providing your information, including without limitation your Personal Data (as defined below), you voluntarily Consent to its use and processing for the purpose for which you provided such Personal Data. “Consent” is defined herein as the express permission that you have provided to us to collect your Personal Data for the business purposes stated herein and subject to the limitations that you provide. We will not sell, distribute, or lease your Personal Data to third parties unless we obtain your prior consent. We will document your Consent to the collection of your Personal Data. You have the right to withdraw your Consent, as detailed below.
Your provision of the foregoing information is voluntary; however, you may need to provide certain information (such as an email address, for instance), in order to access or use certain Website features, and such features will not be available to you if you do not provide such information.
We may also collect information from you automatically when you access, use, or visit the Website, including, without limitation, your IP address, information about your internet connection, information about the equipment you use to access the Website, information collected through cookies and other similar technologies, and your internet usage details.
Types of Personal Data We Collect From You
“Personal Data” includes any information that can be used to directly or indirectly identify an individual, including without limitation IP addresses, names, identification numbers, location data, online identifiers, and/or other information as defined by law, statute, or regulation as “Personal Data.” The “Personal Data” that we may collect from you includes the following:
• Contact Data including your mailing address, email address, and telephone numbers;
• Identity Data including your first name and last name;
• Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences;
• Profile Data including your user name, your password, and any preferences which you set in any user profile;
• Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website;
• Usage Data including information about how you use our Website.
We may also collect aggregated data, such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data under the law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we will treat the combined data as Personal Data in accordance with this Policy.
We do not collect any special categories of Personal Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, information about your health, and genetic and biometric data). We also do not collect any information about criminal charges, convictions, and/or offenses.
Information Collected Through Automatic Data Collection Technologies
As you use, navigate through, and interact with our Website, we may use automatic data collection technologies to collect certain information, which may include data about your browsing actions and patterns as well as your equipment and connection, including without limitation, traffic data, location data, other communication data and resources that you access and use on the Website, information about your computer and internet connection, your operating system, and your browser type. We may also use these technologies to collect information about your online activities over time. Click here for information on how to opt out of this type of tracking if you wish. We may use data collected through automatic data collection technologies to help us improve and customize your Website experience, improve Website navigation, and better serve your browsing needs. The technologies we use for automatic data collection may include the following:
- Web Beacons: Pages of our Website may contain small electronic files known as web beacons, which permit us, for instance, to count Users who have visited such pages, or to gather other, similar Website statistics.
How We Use and Process Your Information We may use and process your information, including without limitation your Personal Data, as follows: (i) to present our Website and its contents to you; (ii) to provide you with information, products, or services that you may request from us; (iii) to fulfill any other purpose for which you provide it, including, without limitation, addressing your concerns, comments, inquiries, or complaints; (iv) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us; (v) to notify you about changes to our products or services; (vi) to allow you to participate in interactive features of the Website; (vii) for any other purpose we may describe when you provide the information; or (viii) for any other purpose, with your Consent. If you have provided us with Consent, we will only use the Personal Data in connection with the reasonable scope of that Consent. If we intend to use that information outside the scope of your Consent, it will notify you to obtain such additional Consent as may be needed.
Please consider and balance any potential impact on you (both positive and negative) before Consenting to our processing of your Personal Data.
Disclosure of Your Information
We may disclose aggregated data about Website Users that does not identify any individual User, without restriction. We may only disclose your Personal Data as follows: (i) to our affiliated companies; (ii) to our contractors, service providers, and other third parties that we contract with to support our business, and who are bound by contractual obligations to keep Personal Data confidential and to use it only for the business purpose for which we disclose it to them; (iii) to fulfill the purpose for which you provide the Personal Data; (iv) for any other purpose disclosed by us when we collect the Personal Data; (v) for any purpose for which you have provided Consent; (vi) in connection with a sale of our business or assets, including sales in bankruptcy or liquidation in which the business will not be continuing as a going concern.
Steps We Take to Protect Your Information
We have implemented and maintain appropriate security measures to prevent your Personal Data from being accidentally lost, processed, or accessed in an unauthorized way, or altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, and contractors who have a legitimate business need to know. They will only use or process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Notwithstanding the foregoing, please be aware that no security measures are perfect or impenetrable; therefore, we cannot and do not guarantee that your information, including without limitation your Personal Data, is absolutely secure and will not be viewed or accessed by others.
Accessing, Correcting, and Removing or Deleting Your Information
Under this Policy, you have the right to review, correct, or delete any Personal Data that you have provided to us via the Website. To do so, or if you have any other questions in relation to this Policy or your Personal Data, please contact us at firstname.lastname@example.org.
Applicability Based On Geographic Location
For individuals that are citizens of the European Economic Area (“EEA”), all processing of Personal Data is made in accordance with the Regulations (“EU”) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”), and our processing of Personal Data will take place in accordance with the GDPR. Similarly, to the extent that the Personal Data is transferred from a data controller outside the EU and/or EEA, we will adhere to the requirements of the GDPR. We will promptly notify you in the event of any known unauthorized access to, or use of, your Personal Data in accordance with all applicable legal requirements.
For individuals who are citizens of states outside the EEA, we have implemented reasonable physical, technical, and organizational safeguards that comply with applicable governing laws, statutes, and regulations.
Retention and Deletion of Personal Data
We will not retain Personal Data for any period of time longer than to fulfill the purpose for which the information was obtained, or as dictated by any applicable law, statute, or regulation. In determining the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the Personal Data, the purposes for which we use or process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, accounting, and reporting requirements.
Links to External Sites
Protecting Children’s Privacy
While we respect everyone’s privacy, we especially respect the privacy of children, and our Policy is intended to adhere to the Children’s Online Privacy Protection Act (COPPA). Our Website is not directed or targeted to, or intended for use by, children or persons under the age of 13, and we do not knowingly collect Personal Data from children or persons under the age of 13. Notwithstanding the foregoing, we realize that a child or person under the age of 13 may attempt to access or use our Website. If you are a parent or guardian and believe that your child is accessing or using our Website, please contact us at email@example.com, and we will delete his/her information within a reasonable period of time. Please note that, before we remove any information, we may ask for proof of identification to prevent malicious removal of account information. You acknowledge and agree that we do not and cannot verify the age of Users, and we shall have no liability for not doing so.
Your Rights to Control Your Personal Data
With respect to the Personal Data that we collect and holds if any, you have the following seven rights: Right to request access to your personal data. This right allows you to request to receive a copy of the Personal Data that we hold about you and to check that we are lawfully processing it.
- Right to request correction of the Personal Data. This right allows you to request to have any incomplete or inaccurate data that we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Right to request erasure of your Personal Data. This right allows you to request that we delete or remove Personal Data where there is no legitimate reason for us to continue processing it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Right to object to processing of your Personal Data. This right allows you to object to our processing of your Personal Data where we are relying on a legitimate business interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Right to request restriction of processing of your Personal Data. This right allows you to request that we suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to request the transfer of your Personal Data to you or to a third party. This right allows you to request that we provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use.
- Right to withdraw consent. This right allows you to withdraw your consent to our processing of your Personal Data at any time where we are relying solely on your consent to process your Personal Data. However, this right does not affect the lawfulness of any processing carried out before you withdraw your consent. If you do withdraw your consent, then we may not be able to provide certain products or services or Website features to you. We will advise you if this is the case at the time you withdraw your consent.
In connection with any request pursuant to these rights, we may request additional information to confirm your identity and to ensure your right to access the Personal Data requested. Any request for additional information is part of our security measures to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You may exercise any or all of these rights at no cost to you. Where practical and not subject to statutory exemption, we will try to respond to all legitimate requests within 30 days of said request. Occasionally it may take us longer than these 30 days to respond if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You also have the right to make a complaint at any time to a regulatory body concerning our processing of your Personal Data. While you have that right, we would appreciate if you first contacted us and afforded us the opportunity to address your concerns before you approach any regulatory body.
For further information concerning your Personal Data or this Policy, please contact us at the email provided above.