Version Date: July 24, 2018
Gathering, Use, and Disclosure of Non-Personally-Identifying Information
USERS OF THE WEBSITE GENERALLY
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, the Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating, and immediately after leaving the Website. Although such information is not Personally-Identifying Information, it may be possible for the Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity, as well as other statistical usage data. The Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help the Company better understand how the Website is being used. By identifying patterns and trends in usage, the Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, the Company may also release anonymized Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. The Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique the Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. Users may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying browser setting to notify users each time a Web Cookie is tendered, permitting users to accept or decline Web Cookies on an individual basis.
The Company may partner with selected third parties to allow tracking technology on the Website, which will enable them to collect data about how users interact with the Website and our services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity.
AGGREGATED AND NON-PERSONALLY-IDENTIFYING INFORMATION
The Company may share aggregated, anonymized Personally Identifying Information and Non-Personally Identifying Information we collect under any of the above circumstances. The Company may also share aggregated, anonymized Personally Identifying Information and Non-Personally Identifying Information with third parties and our affiliate companies to develop and deliver targeted advertising on the Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated, anonymized Personally Identifying Information and Non-Personally Identifying Information with third parties, including advisors, advertisers, and investors, for the purpose of conducting a general business analysis. For example, the Company may tell our advertisers the number of visitors to the Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope users will find of interest and to target content and advertising.
The Company may use hyperlinks on the Website which will redirect users to a social network if clicked on the respective link. However, when users click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and the browser will directly connect to that provider’s servers. If users do not use these buttons, no data will be sent to the respective social network’s plugin provider. So, for example, when you click on the Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within the Company’s control.
The collection, Use, and Disclosure of Personally-Identifying Information
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. The Company may collect a range of Personally-Identifying Information from and about users. Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves when: (1) registering for the service, (2) logging in with social network credentials, (3) participating in polls, contests, surveys or other features of the service, or responding to offers or advertisements, (4) communicating with the Company, (5) creating a public profile, or (6) signing up to receive newsletters. That information may include each user’s name, address, email address and telephone number, and, if users transact business with the Company, financial information such as payment method (valid credit card number, type, expiration date or other financial information). The Company also may request information about users’ interests and activities, gender, age, date of birth, username, hometown, and other demographic or relevant information as determined by the Company from time to time. Users are under no obligation to provide the Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.
BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
The Company may occasionally use names and email addresses of users to send notifications regarding new services offered by the Website. We may also send users service-related announcements from time to time through the general operation of the Website. Generally, users may opt out of such emails at the time of registration or through account settings, though the Company reserves the right to send users notices about their accounts, such as service announcements and administrative messages, even if the user opts out of all voluntary email notifications.
The Company will disclose Personally-Identifying Information under the following circumstances:
- Marketing Communications. Unless users opt-out from receiving Company marketing materials upon registration, the Company may email users about products and services that the Company believes may be of interest to them. If users wish to opt-out of receiving marketing materials from the Company, users may do so by following the unsubscribe link in the email communications, by going to the account settings (if applicable), or contacting the Company using the contact information below.
- Third-Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys and other features offered through the Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
CHANGING PERSONALLY-IDENTIFYING INFORMATION; ACCOUNT TERMINATION
Collection and Use of Information by Third Parties Generally
The Company takes the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures.
The Company is dedicated to protecting all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. The Company does not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally-Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age, on or through the Website, then the Company will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Website, or has otherwise transferred Personally-Identifying Information to the Website, please contact the Company using our contact information below to have that account terminated and information permanently deleted.
California Privacy Rights
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits users who are California residents to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying 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 our privacy officer as listed below.
Personal Data Protection
The Company is committed to protecting the personal data it collects or processes per the Information Security Policy. Additionally, The Company fulfills its obligations under the European Union’s General Data Protection Regulation (EU GDPR). Questions related to EU GDPR and/or data subject rights should be directed to the data privacy officer using the contact below.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.
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