Privacy Policy
Effective Date: January 1, 2020
The Company (“we” or “us”) is committed to protecting the
privacy and security of the information we collect and to
being transparent about the ways in which we collect and
process your information. This statement (the “Privacy
Policy”) sets forth our policies and practices for
handling the information we collect from or about you. It
applies to the websites and online service that we operate
and that link to this Privacy Policy (the “Services”).
I. COLLECTION OF INFORMATION
We collect the following categories of information when
you use our Services (including when you download or
launch our mobile applications) or when the application is
running on your device in the background:
• Information you provide directly to us.
o Contact Information, including name, alias, maiden name,
email address, telephone or mobile phone number, address;
o Sign-In Information, including username and password,
account name, account number;
o Profile Information and Survey Responses, including your
interests, preferences, physical characteristics or
description, feedback, educational or professional
information, employment, employment history;
o Commercial information, including records of products or
services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies;
o Geolocation data;
o Transaction and Billing Data, including bank account and
payment card details, (credit card number, expiration
date, and credit card security code, where needed to
complete a transaction), billing address, delivery
address, signature, transaction history; and
o Correspondence you send to us.
• Information we collect automatically. We collect
internet, electronic activity, and other information
automatically from the devices and browsers that you use,
including your device type; Internet protocol (IP)
address; device and advertising identifiers, probabilistic
identifiers, and other unique personal or online
identifiers; time zone setting and location; browser type
and version; browser plug in types and versions; operating
system and platform; Internet service provider; pages that
you visit before and after using the Services, browsing
history, and search history; the date and time of your
visit; information about the links you click, pages you
view, and advertising you interact with within the
Services and other information about how you use the
Services; the technology on the devices you use to access
these Services; inferences used to create a profile about
preferences, characteristics, psychological trends,
predispositions, behavior, attitudes; and standard server
log information. If you or your device experiences an
error, we collect information about the error, the time
the error occurred, the feature being used, the state of
the application when the error occurred, and any
communications or content provided at the time the error
occurred. Consistent with your mobile device or app
permissions, we also collect geolocation information
including geolocation information derived from your GPS,
WiFi and Bluetooth signals, IP address, and other device
information, photos stored on your device, contacts from
your mobile address book, audio recordings, and
appointments from your calendar.
We also receive the categories of information described
above from other sources, including from users of our
Services, and third-party services and organizations. For
example, if you access any social media or similar
services through the Services to login or to share
information about your experience on our Services with
others, we may collect information from these third-party
services.
Without this information, we are not able to provide you
with all the requested services, and any differences in
services are related to your information.
We may aggregate or de-identify the information described
above. Aggregated or de-identified data is not subject to
this Privacy Policy.
II. USE OF INFORMATION AND PURPOSE OF DATA PROCESSING
We use and otherwise process each of the categories of
information identified above for the following business
purposes:
Purpose
To provide you with the information, products and services
that you request from us; to allow you to participate in
interactive features of our Services, when you choose to
do so; to manage accounts; and to manage our relationship
with you, including providing you with the information,
products and services that you request from us, and
notifying you about changes to our terms or privacy
policy.
To make suggestions and recommendations to you about
things that are similar to those that you have enquired
about or may otherwise be of interest to you, or to send
promotional materials from us or by our affiliates and
trusted business partners.
To improve our Services and to ensure that content is
presented in the most relevant and effective manner for
you and for your device; to administer our Services,
including troubleshooting, data analytics, testing,
research, statistical and survey purposes; to keep our
Services, business and users safe and secure; to comply
with applicable laws and regulations; and to protect or
exercise our legal rights or defend against legal claims.
Where we need to collect information by law, or under the
terms of a contract we have with you and you fail to
provide that data when requested, we may not be able to
perform the contract we have or are trying to enter into
with you (for example, to provide you with goods or
services). In this case, we may cancel a product or
service you have with us.
III. DISCLOSURE OF INFORMATION
We are committed to maintaining your trust, and we want
you to understand when and with whom we may share the
information we collect.
• Authorized third-party vendors and service providers. We
share your information with third-party vendors and
service providers that provide services to us for a
variety of business purposes, such as billing, payment
processing, customer service, email deployment,
advertising and marketing (including counting ad
impressions, verifying positioning and quality of ad
impressions, ensuring compliance with industry standards
and specifications, ad delivery, reporting,
personalization, audience segmentation, and analytics),
security and performance monitoring, maintaining or
servicing accounts, processing or fulfilling orders and
transactions, verifying customer information, research,
data hosting, auditing, and data processing.
• Corporate affiliates. We may share your information with
our corporate affiliates.
• Business transfers. We may share your information in
connection with a substantial corporate transaction, such
as the sale of a website, a merger, consolidation, asset
sale, initial public offering, or in the unlikely event of
bankruptcy.
• Legal purposes. We may disclose information to respond
to subpoenas, court orders, legal process, law enforcement
requests, legal claims or government inquiries, and to
protect and defend the rights, interests, safety, and
security of The Company, our affiliates, users, or the
public.
• With your consent. We may share information for any
other purposes disclosed to you at the time we collect the
information or pursuant to your consent.
If you access third-party services -- such as social media
services, third-party single-sign on tools, mobile
platforms for in-app purchases -- through the Services,
these third-party services may be able to collect
information about you, including information about your
activity on the Services, and they may notify your
connections on the third-party services about your use of
the Site, in accordance with their own privacy policies.
If you choose to engage in public activities on the
Services, you should be aware that any information you
share there can be read, collected, or used by other users
of these areas. You should use caution in disclosing
information while participating in these areas. We are not
responsible for the information you choose to submit in
these public areas.
The Company does not, and will not without consent, sell
your information to third parties. The Company does permit
third parties to collect the information described above
through our Service and discloses such information with
third parties for business purposes as described in this
Privacy Policy, including but not limited to providing
advertising on our Service and elsewhere based on users’
online activities over time and across different sites,
services, and devices (so-called “interest-based
advertising”). The information practices of these third
parties are not covered by this Privacy Policy.
IV. ADVERTISING, COOKIES AND SIMILAR TECHNOLOGIES
When you use our Services, we and our third party
advertising partners (including advertising networks and
exchanges, Internet service providers, data analytics
providers, operating systems and platforms, social
networks, and entities that may sell data) use cookies,
pixel tags, local storage, and other similar technologies
(collectively, “cookies”) to collect information from your
browser or device. By using the Services, you consent to
our use of cookies and similar technologies.
The following types of cookies are used on our Services:
• Essential cookies – These cookies enable you to use our
Services. These cookies are essential to enable you to
browse our Services and use certain features. Disabling
them may prevent you from using certain parts of the
Services. Without these cookies, certain services such as,
recognizing you by name when you return to our Services or
enabling you to use shopping charts with our Services,
cannot be provided. These cookies also help keep our
Services safe and secure.
• Preference cookies – These cookies store information
such as your preferred country and language selection,
login data and website preferences. Without these cookies,
our Services may not be able to remember certain choices
you've previously made (such as a saved country / language
preference) or personalize your browsing experience by
providing you with relevant information. These cookies can
also be used to recognize your device so that you do not
have to provide the same information more than once.
• Performance cookies – These cookies collect information
about how you use our Services such as which pages you
visit regularly. These cookies are used to provide you
with a high-quality experience by doing things such as
tracking page load, site response times, and error
messages.
• Content / advertising cookies – These cookies gather
information about your use of our Services so we may
improve your experience and provide you with more relevant
content and advertising on our Services and elsewhere
online and across your devices. They are also used to
gather feedback on customer satisfaction through surveys.
They remember that you've visited our Services and help us
understand usage of our Services. Some of these cookies
are from third parties that collect information about your
use of our Services in order to provide advertising (on
our Services and elsewhere, across your different devices)
based on your online activities (so-called
"interest-based advertising") on our Services
and elsewhere online, across your different devices. We do
not control the privacy practices of these third parties,
and their practices are not covered by this Privacy
Policy.
Do-Not-Track Signals and Similar Mechanisms. Some mobile
and web browsers transmit "do-not-track"
signals. Because of differences in how web browsers
incorporate and activate this feature, it is not always
clear whether users intend for these signals to be
transmitted, or whether they even are aware of them. We
currently do not take action in response to these signals.
V. YOUR RIGHTS AND CHOICES
You may be entitled, in accordance with applicable law, to
request access to and/or a copy of certain information we
have about you or that we delete certain information we
have about you, or request more information about our
privacy practices. Requests should be submitted in writing
as set out below or by calling our toll free number below.
If you become aware of changes or inaccuracies in your
information, you should inform us of such changes so that
the information may be updated or corrected.
If would like to exercise any of these rights, on or after
January 1, 2020, please submit a request to
[email protected]
or call 1-877-450-9493. You will be required to verify
your identity before we are able to fulfill your request,
for instance by logging into an existing
password-protected online account or by providing us with
two to three pieces of information about you. You may be
entitled, in accordance with applicable law, to submit a
request on your behalf through an authorized agent. To do
so, you must provide us with written authorization or a
power of attorney, signed by you, for the agent to act on
your behalf. You will still need to verify your identity
directly with us.
You may be able to refuse or disable cookies by adjusting
your web browser settings. Some browsers have options
that allow the visitor to control whether the browser will
accept cookies, reject cookies, or notify the visitor each
time a cookie is sent. Because each web browser is
different, please consult the instructions provided by
your web browser (typically in the “help” section). Please
note that you may need to take additional steps to refuse
or disable Local Shared Objects and similar technologies.
For example, Local Shared Objects can be controlled
through the instructions on Adobe’s Setting Manager page.
If you choose to refuse, disable, or delete these
technologies, some of the functionality of the Services
may no longer be available to you and any differences in
service are related to the data. Deleting cookies may in
some cases cancel the opt out selection in your browser.
Some of our third-party partners are members of the
Network Advertising Initiative, which offers a single
location to opt out of ad targeting from member companies.
To learn more, please click here or here. For additional
information on how Google processes your information and
what choices you may have, visit their site here. Due to
differences between websites and mobile apps, you may need
to take additional steps to opt out of interest based
advertising for mobile applications. Please check your
device settings and mobile app permissions for additional
information on how to opt out. You also may stop further
data collection from a mobile application by removing it
from your mobile device.
You also may be able to control our collection and use of
your location information through your mobile device or
app settings.
We will not discriminate against you for exercising your
rights and choices, although some of the functionality and
features available on the Service may change or no longer
be available to you. Any difference in the Services are
related to the value provided.
VI. INTERNATIONAL TRANSFERS
By using the Services and providing us with information,
you understand and agree that we may transfer and store
your information on servers located outside your resident
jurisdiction. To the extent you are a resident of a
country other than the United States, you consent to the
transfer of such data to the United States for processing
by us in accordance with this Privacy Policy.
VII. CHILDREN
We do not knowingly collect or sell any information from
children, as defined by applicable law, without parental
consent or as otherwise permitted by applicable law.
VIII. DATA RETENTION, SECURITY, AND INTEGRITY
Information will be retained only for so long as
reasonably necessary for the purposes set out above, in
accordance with applicable laws.
We maintain reasonable security measures to safeguard
information from loss, theft interference, misuse,
unauthorized access, disclosure, alteration, or
destruction. We also maintain reasonable procedures to
help ensure that such data is reliable for its intended
use and is accurate, complete, and current. You should
understand that no data storage system or transmission of
data over the Internet or any other public network can be
guaranteed to be 100 percent secure, accurate, complete,
or current. Please note that information collected by
third parties may not have the same security protections
as information you submit to us, and we are not
responsible for protecting the security of such
information.
IX. CHANGES TO THE PRIVACY POLICY
We may modify this Privacy Policy from time to time. When
we update the Privacy Policy, we will revise the
“Effective Date” date above and post the new Privacy
Policy. We recommend that you review the Privacy Policy
each time you visit the Services to stay informed of our
privacy practices.
X. CONTACT INFORMATION
If you have any questions about this Privacy Policy or our
practices, please contact us via
[email protected]