Last Updated: March 3, 2022
Personal Information"Personal Information," as used in this Policy, is information that specifically identifies an individual, such as an individual’s name, address, telephone number, or e-mail address. Personal Information also includes information about an individual’s activities, such as information about his or her activity on our Services, and demographic information, such as date of birth, gender, geographic area, and preferences, when any of this information is linked to Personal Information that identifies that individual.
Personal Information does not include "aggregate" or other non-personally identifiable information. Aggregate information is information that we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed. We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes.
We follow the following principles in order to protect your privacy:
- We do not collect any more Personal Information about you than is necessary;
- We only use your Personal Information for the purposes we specify in this Policy, unless you agree otherwise;
- We do not keep your Personal Information if it is no longer needed; and
- Other than as we specify in this Policy, we do not share your Personal Information with third parties.
Collection of Information
We collect Personal Information from you in the following ways. We do so to fulfill our contractual obligations (such as providing the Services) and for our legitimate business purposes (such as improving the Website and Services). We may also collect Personal Information with your consent.
We collect Personal Information that our users provide to us in a variety of ways on our Services. These include the following:
- E-mail Newsletters. We may offer e-mail newsletters from time to time on our Services. If you sign up to receive a newsletter from us, we collect your e-mail address.
- User Accounts and Profiles. Our Services may give you the ability to register for a Company account or to create and update a user profile on the applicable Service. If we offer user-account or profile functionality on the Services, we will collect the Personal Information that you provide to us in the course of registering for an account or creating or updating a user profile. This information may include, for example, name, postal address, telephone number, e-mail address, and related demographic information about you. We may indicate that some personal information is required for you to register for the account or to create the profile, while some is optional.
- Interactive Features. Our Services may contain interactive functionality that allows you to engage with other users on the Services, post comments to forums, to upload user information and other content (the "User Materials") to your account, participate in surveys, and otherwise to interact with the Services and with other users. If you use any interactive functionality on our Services that request or permit you to provide us with personal information (including, for example, any services that allow you to post User Materials on any of our Services), we collect the Personal Information that you provide to us in the course of using these interactive features.
- Correspondence. If you contact us by e-mail, using a contact form on the Services, or by mail, fax, or other means, we collect the Personal Information contained within, and associated with, your correspondence.
When you visit our Services, some information is collected automatically. For example, when you access our Services, we automatically collect your browser’s Internet Protocol (IP) address, your browser type, the nature of the device from which you are visiting the Services (e.g., a personal computer or a mobile device), the identifier for any handheld or mobile device that you may be using, the website that you visited immediately prior to accessing any Web-based Services, the actions you take on our Services, and the content, features, and activities that you access and participate in on our Services. We also may collect information regarding your interaction with e-mail messages, such as whether you opened, clicked on, or forwarded a message.
You may opt out of receiving cookie-based advertising from Google by visiting the Google advertising opt-out page and/or from other third party vendors by visiting the Advertising Initiative opt out page. You may also modify your cookie settings in your browser through your browser settings. Please note that if you set your browser to disable cookies you may not be able to fully access and use the Services.
Also, please be aware that third parties, such as companies displaying advertisements on the Services or sites or services provided by third parties ("Third-Party Sites") that may be linked to from the Services, may set cookies on your hard drive or use other means of passively collecting information about your use of their services, Third-Party Sites or content. We do not have access to, or control over, these third-party means of passive data collection.
Information from Other Sources
We may receive information about you, including Personal Information, from third parties, and may combine this information with other Personal Information we maintain about you. If we do so, this Policy governs any combined information that we maintain in personally-identifiable format.
Use of Personal Information
We may also use Personal Information you provide at any time during your visit to the Website to contact you regarding products, services, and offers, both from ourselves and from third parties, that we believe you may find of interest. We allow you to opt-out from receiving marketing communications from us as described in the "Choice" section below.
Disclosure of Personal Information
Except as described in this Policy, we will not disclose your Personal Information that we collect on the Services to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
We may disclose Personal Information to third-party service providers (e.g., payment processing and data storage and processing facilities) that assist us in our work. We limit the Personal Information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such Personal Information.
Information about our users, including Personal Information, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Information is transferred to one or more third parties as one of our business assets.
To Protect our Interests
We also disclose Personal Information if we believe that doing so is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others, or otherwise to help protect the safety or security of our Services and other users of the Services.
Compliance with Law
We may disclose Personal Information required by law, such as to comply with a subpoena or other legal process, or to respond to a government request.
If you receive promotional e-mail from us, you may unsubscribe at any time by following the instructions contained within the e-mail. You may also opt-out from receiving promotional e-mail from us, and any other promotional communications that we may send to you from time to time (e.g., by postal mail) by sending your request to us by e-mail at firstname.lastname@example.org or by writing to us at the address given at the end of this policy. Additionally, if we offer user account functionality on the Services, we may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us.
Please be aware that if you opt-out of receiving promotional e-mail from us, it may take up to ten business days for us to process your opt-out request, and you may receive promotional e-mail from us during that period. Additionally, even after you opt-out from receiving promotional messages from us, you will continue to receive administrative messages from us regarding our Services.
If we offer the ability to create user accounts or profiles on our Services, you may have the ability to access and update many categories of Personal Information that you provide to us by logging in to your account and accessing your account settings. If you wish to access or amend any other Personal Information we hold about you, you may contact us at email@example.com . We may request proof of your identity before sharing or updating such Personal Information.
If you request that we delete your Personal Information on any of our Services (via a user settings page, by e-mail, or otherwise), we will do so within a reasonable period of time, but we may need to retain some of your Personal Information in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so.
Additionally, if you are in the European Union, you may reach out to us to request a copy of your personal information, to request a transfer of your Personal Information to a third party in certain circumstances, to withdraw any consents that you have provided for processing your Personal Information, or to request that we cease processing your Personal Information. However, please note that it may not be possible for us to cease processing all of the Personal Information we hold if we have another legal basis or requirement for maintaining such information. You also have the right to make a complaint at any time to the relevant data protection authority in your country.
CALIFORNIA PRIVACY RIGHTS AND DISCLOSURES
This summary of California privacy rights and disclosures (this "California Notice") applies solely to residents of the State of California about whom we collect personal information ("consumers" or "you"), including, for example, visitors to our websites and our customers. We adopt this California Notice to comply with the California Consumer Privacy Act of 2018 (as amended, and together with the California attorney general’s implementing regulations, the "CCPA") and any terms defined in the CCPA have the same meaning when used in this California Notice.
Information We Collect
We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). "Personal information" does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Specifically, we have collected the following categories of personal information from our consumers within the last 12 months for the business or commercial purposes described below:
|Description||Examples||Source||Business or Commercial Purposes for Collection|
|Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||Directly from the consumer||Creating accounts and providing our services|
Sending marketing communications
Conducting contests and sweepstakes
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||Directly from the consumer, if any|
|Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, and pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, or genetic information (including familial genetic information).||Directly from the consumer, if any|
|Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Directly from the consumer, if any|
|Biometric information.||Genetic, physiological, biological, or behavioral characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, or sleep, health, or exercise data.||Directly from the consumer, if any|
|Internet or other similar network activity.||Browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.||Directly from the consumer, if any |
Indirectly from the consumer (e.g., through cookies)
Third-party service providers (e.g., data analytics)
In addition to the business or commercial purposes for collection described above, we have in the preceding 12 months collected all categories of personal information described above for the following purposes:
- To process your requests, purchases, payments, and transactions and to prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To create, maintain, customize, and secure your account with us.
- improve this Site and our products and services.
- To provide, support, personalize, and develop this Site and our products and services.
- To help maintain the safety, security, and integrity of this Site and our products, services, databases, other technology assets, and business.
- To deliver content and product- and service-offerings relevant to your interests, including targeted offers and ads through this Site, third-party sites, and via email or text message (with your consent, where required by law).
We will continue to collect the categories of personal information described above for the business or commercial purposes described above. We may also use or disclose the personal information we collect for one or more of the following purposes:
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the users of this Site is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosures of Personal Information for a Business Purpose
In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
- (A) Identifiers.
- (B) California customer records.
- (C) Protected classification characteristics.
- (D) Commercial information.
- (E) Biometric information.
- (F) Internet activity.
We disclose your personal information for a business purpose to the following categories
When we disclose your personal information to a service provider, we enter into a contract with the service provider that describes the business purpose for which your personal information is disclosed and restricts the service provider from using your personal information for any purpose other than providing the services under the contract.
Sales of Personal Information
In the preceding 12 months, we have not sold personal information.
Your Rights and Choices
The CCPA provides you, as a California resident, with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed for a business purpose or sold your personal information, two separate lists disclosing:
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Sales, identifying the personal information categories that each category of recipient purchased.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- 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 the information’s deletion may likely render impossible or seriously impair the research’s
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at (800) 331-0876.
- Emailing us at firstname.lastname@example.org.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the personal information requested.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless the request is excessive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- 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, including denial of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California’s "Shine the Light" law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us through the information set forth below.
Changes to this California Notice
We reserve the right to update or change this California Notice at any time. When we make changes to this California Notice, we will post the updated notice on this Site and update the date on which this California Notice was last updated. The date this California Notice was last updated is at the top of this page. You are responsible for periodically reviewing this Site and this California Notice to check for any updates or changes. Your continued use of this Site following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this California Notice or our privacy practices, your choices and rights regarding use of your personal information, or wish to exercise your rights under California law, please contact us at: