Company automatically collects the following information about your interactions with the Platform (collectively, “User Data”):
By accessing the Content though the Platform, you agree that we may share or otherwise provide the User Data to any third-party for any purpose permitted by law.
Without limiting the above, you agree that Company may share aggregate or group data about Users of the Platform with third parties, including advertisers and their agents, for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Platform Users as a group, without disclosing personally identifiable information.
We may provide the User Data to third-party companies and individuals to perform certain functions on our behalf (“Third-Party Service Providers”). Examples include data storage and processing, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to User Data as needed to perform these functions for us, but we do not permit them to use User personal information for other purposes.
We will also use your personal information with your permission, for customer service, to customize your experience with the Platform and/or to contact you when necessary in connection with your use of the Platform. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Platform. We may also combine the information we have gathered about you with information from other sources.
We reserve the right to release current or past personal information: (A) in the event that we believe that the Platform is being or has been used in violation of the Terms and Conditions or to commit unlawful acts; (B) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; or (C) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Company is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Platform of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.
You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with third-parties for suppression purposes in compliance with applicable law, including the CAN-SPAM Act of 2003, as amended from time to time. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third parties without permission.
In general, Users may be able to disable some, or all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. In addition, Users may be able to opt-out of this form of tracking by utilizing the options made available by:
Further, Users can opt-out of certain Google®-related tracking technology, and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http ://www.google.com/settings/ads. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third-parties, including Google®, in connection with the Platform.
We endeavor to safeguard and protect our Users’ personal information. When Users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline).
Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. Access to all of our Users’ personal information is restricted on our premises, as well as the premises of our Third-Party Service Providers, such as our data hosting services. Only employees or third-party agents who need User personal information to perform a specific job are granted access to any User personal information. Our employees are subject to policies designed to ensure the security and privacy of all User personal information. Employees not adhering to our firm policies are subject to disciplinary action.
Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; note, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data to or through the Platform, is done at your own risk.
In compliance with applicable laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach of our premises or Platform servers with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures. For personal data stored by our Third-Party Service Providers, such Third-Party Service Providers shall be responsible for notifying you of any information security breach of their premises or servers, in accordance with applicable law.
Company does not knowingly solicit or collect information from Users under eighteen (18) years of age.
At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by e-mailing us at: email@example.com. Before processing such requests, and, to the extent permitted by applicable law, we will require individual Users to identify themselves and the information requested to be accessed, corrected or removed we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing only on backup storage media).
Please be advised that deleting your personal information may terminate your access to certain functionality of the Platform.
Please be further advised that, after you delete your personal information, residual copies may remain in our backup systems and it may take a period of time before they are deleted from our active servers.
We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers.
B. 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, postal 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.
C. 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, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
F. Internet or other similar network activity.
Browsing history, search history, information on a User’s interaction with a website, application or advertisement.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
Personal information does not include:
We may obtain such personal information from one or more of the following categories of sources (with the specific categories of personal information indicated in parenthesis):
We may use or disclose the personal information that we collect to fulfill or meet the reason for which the information is provided, such as:
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 with notice.
Sharing Personal Information
Subject to your right to opt-out of such sharing, we may share your personal information with/to third parties for marketing purposes, as well as other business purposes. When we disclose personal information to a third party, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of Users that we actually know are less than eighteen (18) years of age in the preceding twelve (12) months.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
No information disclosed in the preceding 12 months
In the preceding twelve (12) months, we have sold the following categories of personal information to third parties:
No information has been sold in the preceding 12 months
We may disclose your personal information for a business purpose to the following categories of third parties (Category A, B, C, F and I)
In the preceding twelve (12) months, we have not: (a) sold personal information (including (i) e-mail address; (ii) full name; or (iii) telephone number; to the third parties who purchase and/or license your personal information for marketing purposes; or (b) shared your personal information for the business purposes set forth above.
In the preceding twelve (12) months, we have:
Your Rights and Choices
The CCPA provides CA Users with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Opt-Out from the Sale of Your Personal Information
You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:
Where you make a request to opt-out of the sale of your personal information through an Authorized Agent, we will require that you or the Authorized Agent provide us with a valid written authorization executed by you and that Authorized Agent, with the validity of such document determined by us in our reasonable, good faith discretion. Please submit such documentation to us by:
We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request.
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 twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:
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 CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Exercising Access, Data Portability and Deletion Rights
To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information. Where you make a data deletion request, data portability request and/or information access request through an authorized agent, we will require that you or the authorized agent provide us with a valid written authorization executed by both parties, with the validity of such document determined by us in our reasonable, good faith discretion. Please submit such documentation to us by:
You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:
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 that the personal information relates to you. Making a verifiable CA User request does not require you to create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. 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 twelve (12) month period preceding the receipt of your verifiable 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 CA User request unless it is excessive, repetitive, or 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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Changes to these Provisions
We reserve the right to amend these Provisions in our discretion and at any time. When we make changes to these Provisions, we will notify you by email or through a notice on the Platform.
Additional Provisions for European Residents
Company is considered the “data controller” for its Platform as defined within Regulation (EU) 2016/679 (General Data Protection Regulation)(“GDPR”). You, the User, are the “data subject.” The following agreement applies solely to personal data held by Company within the Platform, or in Company’s internal records relating to the Platform.
Your data can only be processed if there is at least one lawful basis to do so. The lawful bases for processing data are:
We obtain the following personal information with your consent on our Platform:
It is the responsibility and liability of Company, as the data controller, to implement effective measures and to comply with applicable law in its data processing activities, and Company hereby acknowledges such responsibility.
As described above, depending on how you interact with our Platform, and what consent you have given, we may have some or all of the following personal data stored about you:
Upon a reasonable advance written request to us, and upon verification of the request being genuine, you have the right to access and correct such personal information in our possession.
If you as a User of our Platform request in writing that we delete your personal data, upon verification of the request being genuine, we shall delete or render illegible all your requested personal data within a reasonable time (not to exceed five (5) business days). Should this request result in the inability for us to provide a service or functionality to you, we will inform you of the potential impact prior to performing the erasure.
In addition, visitors to the Platform who are not contracted customers will have their personal data erased automatically after two (2) years if they do not continue to interact with the Platform or with emails sent by us.
If you as a User of Our Platform request in writing that we provide you a copy of your personal data, upon verification of the request being genuine, we will provide your personal information in an industry standard format that will allow you to use it somewhere else.
We have implemented appropriate security measures to prevent, address and rectify unauthorized access to personal information. These measures include, without limitation, hardware and software firewalls; the physical security of our server locations; encryption of all personal data transmitted into and out of our servers; and policies and training of all personnel having access to personal information.
Company maintains records of its data processing, which include the purposes of the processing, the categories of data involved and the duration of the data retention period. These records are available to the applicable supervisory authority on written request to ss.
We will report to the relevant supervisory authority within 72 hours, as well as to affected Users, if we determine that there has been a data breach of our Platform servers.
We do not, as our core activity, handle the data processing of operations that require regular and systematic monitoring of data subjects, therefore we do not have a formal Data Protection Officer for our Platform.
Because Company is not established in the EU, it designates the individual below as its representative in the EU with regard to its obligations under the GDPR. Supervisory authorities and data subjects should direct all communications regarding Company’s GDPR compliance to the following: