Effective Date: January 1, 2020Last Reviewed on: January 1, 2020
Information We Collect From You
We may collect two types of information from you: Non-Personally Identifiable Information (“Non-PII”) and Personally Identifiable Information (“PII”).
What is Non-PII?
Non-Personally Identifiable Information does not individually identify you. Rather, it is anonymous technical information about users’ visits to the Site and certain other internet properties, used to evaluate and enhance the Site’s services and to offer you products and services which may be relevant to you. Your Non-PII may be utilized individually or aggregated with other users’ Non-PII. Non-PII collected from you may include, without limitation: the IP address assigned to your computer or other device and other general location information; the type of internet browser and operating systemyour computer or other device is using; your time of visit to, and how long your visits lasts on, the Site; anonymous, demographic data about you, such as the potential age range or household income range which you might fall under; unique device identifiers; and other transactional information related to your use of the Site and certain other internet properties through the use of “cookies”, “web beacons”, or other tracking technologies, such as a session ID or your use of a particular online service over time and across multiple websites.
How is Non-PII Collected?
Non-PII is generally collected automatically by using the Site or other internet services, though you may control the collection of certain information, such as by setting your browser to block cookies or by opting out of certain interest-based advertising, as described more fully below,in the section titled, “How Can You Limit the Collection and Use of Your Non-PII?”.
Is Non-PII Reidentified?
Yes. If utilized in an non-aggregated way, Non-PII is associated with an individual but it is not generally linked to any PII such that the identity of that individual can be reasonably determined. However, the Site may, from time to time, utilize information collected from the Site, other web properties associated with the Site, or from third parties in order to link Non-PII with other Non-PII, or Non-PII with PII, in order personally identify you.
What is PII?
By contrast, Personally Identifiable Information is information that does personally identify you. It includes, without limitation, your name, email address, physical address, phone number, and email address, or Non-PII that has been linked to such PII.
How is PII Collected?
In order to collect PII from you on the Site, you must submit the PII voluntarily. If you do not want us to collect such information, you should not submit it to the Site. However, doing so may restrict your ability to use the Site. Although we do not collect PII from you on the Site without your consent, we may otherwise lawfully obtain information from reputable third partiessuch as companies who provide publicly-available information or other Non-PII which is then linked to your PII.
How We Use Your Information
Do We Use Your Non-PII Internally?
Yes. As touched on above, we utilize Non-PII in a number of ways. Typically, it is used internally in an aggregated way to analyze and report on the ways in which the Site is used and how we can improve the user experience and improve the Site’s performance and services. We may analyze an individual user’s Non-PII for the same reasons.
Do We Share Your Non-PII With Third Parties?
Do Third Parties Have Their Own Collection and Use Practices?
Yes. Certain Vendors provide data, analytics, and marketing services (such as Google Analytics, an ad server, or a third party marketing partner) and may employ their own technologies for collection of information on the Site. While a Vendor may not generally implement a collection technology without our consent, we do not control the Vendors’ technologies, how they may be used, or the information they may collect, and we are not responsible for the privacy policies or the content of the Vendors. Please visit the sites of those businesses to review their privacy policies.
What Information Do Cookies Collect?
A “session” cookie will store information about your activity on the Site until the browser is closed, at which point the session cookie may be deleted. A cookie may also store information about your activity on the Site beyond the closing of the browser, such as by storing your password or other information so that you don’t have to re-enter it each time. Typically, our cookies will expire after 30 days of inactivity.
Do We Engage in Marketing, Interest-Based Advertising, and Retargeting?
Yes. We, our Vendors, or Partners (defined in the section below titled, “Do We Share Your PII With Third Parties?”) may set a cookie on your device to provide you with interest-based or “targeting” advertising. Such tactics may includetracking your use of a web service over time and across different websites, in what is known as “retargeting” which is a type of interest-based advertising. Retargeting means that after visiting the Site, third parties may deliver ads to you on other websites based on your interest in, or activity on this Site. Conversely, you may be shown ads on this Site based on your interest in, or activity on, third parties’ websites.Our advertising partners do not have access to or use your PII from us, without your consent, except as otherwise provided herein. As discussed above, they may track your Internet usage across other websites and combine data from other sourcesto personally identify you, outside of our knowledge and control.
Do We Use Your PII Internally?
Do We Share Your PII With Third Parties?
Yes. We may use your PII for any lawful purpose. For example, We may need to share your PII with our Vendors who provide services to us so that we can operate the Site and provide the Site’s services. Such Vendors may not utilize your PII for any other purpose, and their use of your PII is subject to their confidentiality agreement with Us. We may also share, sell, rent, or license your PII to other third parties, such as advertisers and marketers, for the purpose ofproviding their products and servicesto you (“Partners”).If You subsequently decide that you no longer want Partners to utilize Your PII, You will have to communicate Your request directly with Partners, as We do not have control over their policies or business practices.
May We Assign Your Information to Another Company?
Are There Other Circumstances Under Which We Might Share Your Information?
Yes. There are other circumstances under which we might share your information, generally when there is a legal issue or when attempting to resolve a dispute. We may disclose any of your information to third parties: when we reasonably believe we are obligated to do so by law, including without limitation, by contract, search warrant, subpoena, or court order; to investigate, prevent, or take action regarding suspected or actual prohibited activities, including without limitation,fraud, situations involving potential threats to the Site or the physical safety of any person or the public, or violations of applicable law; to protect our and third party rights; and to communicate with service providers who may assist us in responding to your inquiries, requests, or disputes.
Your Choices and Control Over the Collection and Use of Your Information
We believe you should have choices about the collection, use, and sharing of your information. Although you cannot opt-out of all data collection, you can limit the collection, use, and sharing of some of your information.
How Can You Limit the Collection and Use of Your PII?
As stated above, if you do not wish for us or third parties to collect your PII, you should not submit PII into the Site. The very nature of some of the services the Site offers requires your PII. Therefore, if you do not submit PII you may not be able to use the associated services. You may also email firstname.lastname@example.org to request access or changes to your PII; however, you will not be permitted to examine the PII of any other person or entity and may be required to provide us with PII to verify your identity prior to accessing any records containing information about you. We may not accommodate a request to change or delete PII information if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.
Opting Out of Email Marketing Communications
You may opt-out of receiving email marketing communications from us by sending an email to email@example.com or by following the opt-out link in the emails you receive. Upon your opt-out, please allow up to 10 business days for the opt-out to go into effect. Please note that you may not be able to opt-out of transactional communications which are required as a part of your account but which are not meant to offer you products or services. Also note that our Vendors or Partners may send you email marketing communications or advertising offers through other mediums. Your opt-out request to us may not affect whether third parties continue to market to you. In those scenarios, please contact those companies directly.
How Can You Limit the Collection and Use of Your Non-PII?
There are several ways you may limit the collection and use of your Non-PII. First, you may modify your browser’s cookie settings. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your web browser to decline cookies, some features of the Site may not work or may not work as designed.
Browser “Do Not Track” Functionality
Opting Out of Interest-Based Advertising
As described above, we, our Vendors, or our Partners may engage in what is known as interest-based or targeted advertising. You may opt out of the collection of your information for purposes of interest-based advertising. For more information about interest-based ads, please visit http://www.allaboutcookies.org/. To opt out of your web browsing information being used in this manner, please visit http://optout.aboutads.info. This opt-out process is managed and governed by industry self-regulatory bodies such as the Digital Advertising Alliance (http://digitaladvertisingalliance.org/), not by us. Note that in the opt-out process, you may opt-out of interest-based advertising on a company-by-company basis, or you may opt out of interest-based ads from all companies who have elected to participate in the program. Although some companies may provide their own, direct opt-out mechanism, this Site does not currently offer that option. If you do elect to take advantage of this opt-out, it remembers your preference by setting a cookie on your device or browser. Therefore, if you change computers or browsers, or delete cookies, you will have to opt-out again for each of the companies you previously opted out of. It is also important to note that opting-out of interest-based ads does not mean that you will no longer receive advertising, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms.
Governing Law and Notice to Non-U.S. Users
How Your Information Is Retained and Secured
We take commercially reasonable security measures to protect your PII, including the use of physical, technical, and administrative controls. Please understand, however, that while we try our best to safeguard your PIIonce we receive it, no computer system, network, or transmission of data over the Internet can be guaranteed to be 100% secure. You need to protect the privacy of your own information. You must take precautions to protect the security of any information that you may transmit over any computer networks by using encryption, secure networks and websites, and other techniques to prevent unauthorized persons from intercepting or receiving any of your information. You are responsible for the security of your information when using unencrypted, open access or otherwise unsecured networks. Please also keep your passwords strong and secure, keep your security software and computer systems up to date using industry best practices, and always be vigilant and informed when sharing your information on the Internet.The time period for which we keep information varies according to the purpose for which it is used for. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.
Third Party Sites
Information Relating to Children
The Site is not intended for or directed at children under 13 years of age. We do not knowingly collect PII from children under 13 years of age. If you are under 13 years of age, do not use this Site or provide your PII to us. If we discover that a child under the age of 13 has provided us with PII, or that we have inadvertently collected such information, we will promptly delete it. If you believe that we have been provided with the PII of a child under the age of 13, please notify us immediately at firstname.lastname@example.org.
Your California Privacy Rights
Under California law, residents of California may request certain information about our disclosure of PII during the prior calendar year to third parties for marketing purposes. To request this information, please contact us at email@example.com.
|A. Identifiers. (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.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). (Related Information)||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.||YES|
|C. Protected classification characteristics under California or federal law. (Characteristics)||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, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information. (Commercial Information)||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information. (Biometric Information)||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity. (Internet Activity)||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data. (Geolocation data)||Physical location or movements.||YES|
|H. Sensory data. (Sensory data)||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information. (Professional Information)||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). (Non-public Education Information)||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information. (Inferences)||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- 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) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you (e.g., via telephone, text message, email, website form submission, etc.).
- Publicly accessible sources (e.g., property records, public directories, etc.).
- Third parties (e.g., marketing vendors and social media, digital advertising, and data aggregation businesses).
- Indirectly from you (e.g., via cookies, digital trackers, analytics, and IT and security systems).
Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share
- To fulfill the reason you provided the information (e.g., to match you with an insurance agent, provide support, respond to an inquiry, etc.).
- To market products and services to you (including by third parties with whom we may share your personal information).
- To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites and companies, and via email, telephone, text message, or other means (with your consent as required by applicable law).
- For other marketing purposes.
- To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
- To evaluate or conduct a merger, restructuring, sale, or other corporate transaction in which personal information is among the assets transferred.
- To investigate and prevent fraud and abuse of our website, products, and services.
- To comply with our legal and regulatory obligations.
- For other business purposes.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
- Persons or companies that offer products or services on our websites (Providers).
- Marketing vendors and social media, digital advertising, and data aggregation companies (Marketers).
- Auditors, attorneys, consultants, professional service providers, etc. (Professional Services).
- Other parties with a legal interest (including private parties and government or regulatory entities) (Legal Parties).
- Other service providers we use to help provide our products or services (Service Providers).
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed for a business purposeIdentifiers, Related Information, Characteristics, Internet Activityand Geolocation Data to Providers and Marketers.
Sales of Personal Information
In the past twelve (12) months, we have disclosed for business purposes Identifiers, Related Information, Characteristics, Internet Activity, Geolocation Dataand Inferences to Professional Servicesand other Service Providers.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their 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, 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 or selling 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 sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
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, 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 provider(s) to:
- Complete the transaction for which we collected the personal information, 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 their 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.).
- 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 that 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 sending us an email to firstname.lastname@example.org. Only you, or a person registered with the California Secretary of State that you authorize 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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. 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 verifiable consumer request’s receipt. 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, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, 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.
Personal Information Sales Opt-Out and Opt-In Rights
We do not knowingly collect information from individuals under eighteen (18) years of age. No information should be submitted to, or posted at, our websites by individuals under eighteen (18) years of age.Consumers who opt-in to personal information sales may opt-out of future sales at any time. To request that we do not sell your personal information, click the Do Not Sell My Personal Information hyperlink located near the bottom of the landing page on our website.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.
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.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are 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 send us an email to email@example.com or write us at our address listed on our webpage.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which we collect and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows:
- By emailing – firstname.lastname@example.org
- Write us at our address listed on our webpage.