Last updated: Jan 1st, 2021
Categories of Personal Information Collected. Generally, we collect the following types of personal information:
Use of Personal Information. In general, we may use and disclose the personal information we collect for the following business and commercial purposes:
California residents: If you are a California resident, please refer to the California Privacy Disclosures section below for important information about the categories of personal information we collect and disclose, as well as your rights under California privacy laws, including your right to submit a “Do Not Sell My Info” request (i.e., to opt of the sale of your personal information by us).
The personal data that we collect when you visit our Sites or use our Services may include the following:
We collect personal data directly from you, automatically through your use of our Sites and Services, or from third parties. For example, we collect personal data:
Certain laws, including the EU General Data Protection Regulation, require that we inform you of the legal bases for our processing of your personal data. Accordingly, we collect and use your personal data for the purposes described below and on the following lawful bases:
Purpose for using personal data. While the purposes for which we may process personal data will vary depending upon the circumstances, in general we use personal data for the purposes set forth below. Where GDPR or other relevant laws apply, we have set forth the legal bases for such processing (see above for further explanation of our legal bases) in parenthesis.
We do not share your personal data other than as described in this paragraph:
In order to protect your personal data we have implemented reasonable, commercially acceptable security procedures and practices appropriate to the nature of the personal data we store, in order to protect it from unauthorized access, destruction, use, modification or disclosure. Your personal data is contained behind secured networks and is only accessible by a limited number of people, who have special access rights and are required to keep the personal data confidential.
Please keep in mind that no website or internet transmission is completely secure. Therefore, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe, such as closing your web browser when finished using the Sites.
Our Sites and Services are not directed to anyone under the age of 16, and we do not knowingly collect personal data from minors under the age of 16.
You can manage your preferences regarding third party ad company cookies deployed on our Site by using our cookie preference manager.
We will generally retain the personal data we processed through our Sites and Services for as long as it is required for purposes for which the data were collected. Unless we inform you otherwise, this will usually be the period of 3 years after the last interaction with you plus the length of any applicable statutory retention period following such activity.
Your personal data may be transferred to -and maintained on- computers located outside of your state, province, country or governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside the USA, please note that the personal data you provide (as described above under "What Personal Data Do We Collect") will be transferred to the USA, where the level of data protection may not be equivalent to the level of protection applicable at your location.
Where we are legally required to do so, transfers of personal data to parties outside the EU/EEA may be made pursuant to the European Commission-approved Standard Contractual Clauses or other legally acceptable mechanisms that ensure an adequate level of protection. Where applicable, you are entitled to receive a copy of the relevant contract (such as Standard Contractual Clauses or Binding Corporate Rules) showing that appropriate safeguards have been taken to protect your personal data during such transfer.
In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA. Importantly, this section also does not apply to our handling of customer data (including any personal information contained therein) that is uploaded to the Site or that is provided as part of the Service, where we are acting as a service provider or processor (depending on applicable privacy law).
Personal Information under the California Consumer Privacy Act (CCPA). We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
California Privacy Rights. If you are a California resident, you have the right to:
In order to protect your privacy and verify your request, we may require additional information from you. Please note that these rights are subject to certain exceptions under applicable law.
Instructions: You or your authorized agent can submit your request by emailing us at firstname.lastname@example.org, or calling us at 1-877-989-7372 (toll free). If you have questions or concerns about our privacy practices, you may contact us at email@example.com.
Categories of Personal Information Collected and Disclosed: The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the Purpose for using personal data section above.
|Personal Information Collected||May We Disclose this Information?||Categories of Third Parties to Whom We May Disclose this Information|
|Identifiers||Includes direct identifiers, such as name, alias user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers.||YES||
|Customer Records||Includes personal information, such as name, account name, user ID, contact information, education and employment information, payment information that individuals provide us in order to purchase or obtain our products and services.||YES||
|Commercial Information||Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.||YES||
|Audio, Video and Electronic Data||Includes audio, electronic, visual, thermal, olfactory, or similar information such as photographs and images (e.g., that you provide us) and call recordings (e.g., of customer support calls).||YES||
|Usage Data||Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other services, and our marketing emails and online ads.||YES||
|Professional information||Includes professional and employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships).||YES||
|Education Information||Information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates).||YES||
|Inferences||Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes.||YES||
Do We “Sell” Personal Information? Under the CCPA, a “sale” includes disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value. While we do not disclose personal information to third parties in exchange for monetary compensation, we may disclose or make available certain categories of personal information to third parties in order to receive certain benefits or services, such as when we make browsing information available to third party ad companies (through third party tags on our Websites) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. As defined by the CCPA, we may “sell” Usage Data and Identifiers to third party advertising networks, social networks and data analytics providers. To opt of our sale of your personal information, you may click on Do Not Sell My Info.
Sources: We collect the above categories of personal data from the sources described in Sources of Personal Data We Collect (above) and for the purposes described in Purposes For Which We Use Personal Data (above).
Financial Incentives: We currently do not offer financial incentives to California residents related to use of personal information. If we make available certain programs or offerings that are considered “financial incentives” under the CCPA, we will provide you with a description of the material terms of such program(s) so that you may choose whether or not you would like to participate. We will not opt you in to any financial incentives without your prior consent, and you may subsequently opt out any anytime.
For any questions or concerns about our privacy policies or practices, you can contact firstname.lastname@example.org.
Residents of the EU and EEA have the following rights under the GDPR regarding their personal data. We will take steps in accordance with applicable legislation to keep your personal data accurate, complete and up-to-date. You are entitled to have any inadequate, incomplete or incorrect personal data corrected (that is, rectified). You also have the right to request access to your personal data and to obtain a copy of it as well as additional information about the processing and to request us to erase the personal data we hold about you. In cases where we rely on your consent for using your personal data, you can withdraw such consent at any time by sending an email to: email@example.com.
The following rights apply in addition to the above to European residents:
For further information regarding your rights, or to exercise any of your rights, please contact us at firstname.lastname@example.org or see section ‘How you can contact us’ for more details. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
If you are a Canadian resident we have the right to send you commercial electronic messages ("CEM's") under certain conditions. We are committed to ensuring that all applicable recipients of our CEM's receive them in a manner that is consistent with Canada's Anti-Spam Legislation. We will continue to send CEM's to applicable recipient in the following contexts:
In the event you no longer wish to receive CEM's from us, email us at email@example.com or reply to the electronic message / email address sent to you with the word "Unsubscribe", you may also use the unsubscribe button provided for in every email we send. Our CEM's also contain information on how to unsubscribe from receiving CEM's. Your request will be processed as soon as possible, and no later than ten (10) days after you send the request.