IMPORTANT: PLEASE READ CAREFULLYEffective as of February 14, 2020.
You may also email us at firstname.lastname@example.org with any privacy-related questions you have.
There are three basic categories of information we collect:
Personal Information you provide to us
Information we get from third parties
We may collect Personal Information that you choose to share with us. For example, when you set up an account, we need to collect important details about you, such as your name, phone number, date of birth, unique username, location, social security number, and email address. We may also collect any communications between you and Company and any other information you provide to Company. To help the government fight the funding of terrorism and money laundering activities, we obtain, verify and record information about beneficial owners, including you, of Clients and other permitted users of Services. This means that when you access or use our Services, we may ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see other identifying documents, such as a driver's license. If, for any reason, you are unable to provide the information necessary to verify your identity, you are not permitted to access or use the Services. Please ensure that you only send us an image of yourself. Do not include any images of others.
We, and our third-party partners, collect certain Personal Information automatically when you visit our online services, read our e-mails, access or use our Services, or otherwise engage with us. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and other technology (collectively, "Tracking Technologies").
We, and our third-party partners, use these Tracking Technologies and other tools to automatically collect usage and device information, such as:
Your IP address, location, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, your internet service provider, and other such information.
We also collect information about the way you use or access our Services, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Services, whether you open e-mails or click the links contained in e-mails, whether you access the Services from multiple devices, and other actions you take on the Services.
When you access our Services from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers ("IDFA"), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device's location by analyzing other information, like an IP address.
Do Not Track Signals. We are unable to respond to Do Not Track signals set by your browser at this time. If you would prefer not to accept cookies, most browsers will allow you to (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies and these browser settings that block cookies may have no effect on such techniques. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about - including how to manage privacy and storage settings for Flash cookies - on Adobe's website. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.
We may collect Personal Information about you from other users, our affiliates, and third parties, as permitted by law. For example, we may collect information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly available sources to verify your identity. We may also collect information about you from third parties in connection with any identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law.
To provide the Services, we may use your Personal Information to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
Create and process an account for you and deliver the Services to you and manage individual information and accounts;
Respond to questions, comments, and other requests;
Verify an individual's identity by comparing your selfie image against your government-issued identification;
Send you transactional information, including confirmations, invoices, technical notices, product and services information, updates, security alerts, support and administrative messages, and information about your transactions using the Services;
Process payment for products or Services purchased;
Process applications and transactions;
Provide access to certain areas, functionalities, and features of our Services;
Communicate with you, such as to respond to your comments and questions, provide customer service or feedback, or respond to employment opportunities for which you've applied, of for any other purposes in connection with the Service;
Facilitate any transaction requested by you; and
Allow you to register for events.
For internal business purposes, we may use Personal Information for its internal business purposes, including to:
Conduct research and analytics to understand our visitors and customers, and tailor our product offerings;
Operate, maintain, test, enhance, update, monitor, diagnose, fix and improve our Service;
Develop new products and Services or improve existing products and Services;
Ensure internal quality control;
Communicate about individual accounts and activities on our Services and systems, and, in our discretion, changes to any our policy;
Comply with regulatory and legal requirements;
Prevent, investigate or provide notice of fraud or unlawful or criminal activity, and enforce and carry out contracts and agreements between us and you;
Protect the safety of any person, to address fraud, security or technical issues, or to protect our rights or property; and
For any other purpose for which you have given express permission or consent to us.
For marketing purposes, we may analyze and use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, email, as permitted by applicable law. Such uses include:
To provide you with, and to tailor, content, advertisements, and offers;
To notify you about offers, products, and services that may be of interest to you;
To provide Services to you and our partners and affiliates;
For other purposes disclosed at the time you provide Personal Information;
Facilitate contests, promotions and rewards and provide you with news about products and services offered by us and our selected partners; and
Otherwise with your consent.
We may share your Personal Information in the instances described below.
To verify your identity. For example, we may share information about you with credit reporting agencies, financial institutions or government agencies to verify your identity or to otherwise establish eligibility for a product or our Services;
With vendors and service providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; (iv) customer service activities; (v) fraud prevention; (vi) analytics services; and (vii) in connection with the provision of the Services;
We may share Personal Information with our business partners, affiliates, and for our affiliates' internal business purposes or to provide you with a product or service that you have requested. We may also share Personal Information with business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you;
With third parties for legal reasons. We may share information about you if we reasonably believe that disclosing the information is needed to: (i) comply with any valid legal process, governmental request, or applicable law, rule, or regulation; (ii) investigate, remedy, or enforce potential Terms of Service violations; (iii) protect the rights, property, and safety of us, our users, or others; or (iv) detect and resolve any fraud or security concerns;
With third parties as part of a merger or acquisition. Your Personal Information may also be one of the transferred assets as part of a merger, acquisition or bankruptcy; and
As otherwise permitted by law, including the Gramm-Leach-Bliley Act.
We may participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history or other information. We may share or we may permit third-party services to collect information about your use of our website over time so that they may play or display ads on our website, online platform or in connection with our Service, on other devices you may use, and on other websites, apps, or services. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information. A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services, including helping us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third-party partners who employ tracking technologies or the application of statistical modeling tools to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.
We may use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, log in to your account on our Service, or otherwise engage with us. We may share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site "How Google uses data when you use our partners' sites or apps" located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics' currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
Please review the section title 'Your choices' below to understanding your choices regarding third party tacking and online advertising.
We will retain your information for as long as you use our Services, to resolve disputes, establish legal defenses, conduct audits, enforce our agreements, comply with applicable laws or as long as we otherwise deem appropriate. We also maintain your Personal Information as part of our standard backup procedures.
Our Services may contain links to other websites and other websites may reference or link to our Services. These websites are operated by third parties not controlled by us, and by linking to them or being linked from them, we do not endorse, approve or make any representations about third-party websites or domains. We encourage you to read the privacy policies of each and every website and domain that you interact with. We are not responsible for the privacy practices or content of such other websites or domains and you visit them at your own risk.
Our Services may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible social media platform, blog, or chat room, or otherwise online, or that you share in an open forum, may be viewed and used by others without any restrictions. We have no control over such uses of your information when interacting with a social media platform, forums or otherwise online and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties.
Data storage and transfer: Your information collected through our Service may be stored and processed in the United States or any other country in which Company or its parent, subsidiaries, affiliates, or service providers maintain facilities or otherwise stores information. If you are located in other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. In addition, information collected about you may be stored on the block chain or using cloud-based services. Information recorded on the block chain or information stored in the cloud may be maintained by third-party networks in locations in which such third-party networks operate or maintain data storage or processing facilities.
Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
We may give you choices regarding the sharing of your information with affiliates and third parties. Choices you have about the sharing of your information will be described in the privacy policies or notices you receive in connection with the products or Services you obtain from us.
Cookies and Flash cookies. Most browsers allow you to adjust your browser settings to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.
Blocking or deleting cookies may negatively impact your experience using the Service, as some features and services on our Service may not work properly.
Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. To manage Flash cookie settings and preferences, you must use the settings manager on Adobe's website. If you choose to delete Flash objects from our Service, then you may not be able to access and use all or part of the Service or benefit from the information and services offered.
Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative's online resources at http://www.networkadvertising.org/choices and/or the DAA's resources at www.aboutads.info/choices.
Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI's and DAA's online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest based ads" (Android). You may also be able to opt-out of some - but not all - interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, please let us know by contacting us at email@example.com. If we learn that we have collected any personal information from children under 13, we will use commercially-reasonable efforts to delete such information.
If you are a user of the Services and a California resident, California's "Shine the Light" law (California Civil Code §1798.83) permits you to request and obtain from us once a year, free of charge, information regarding our disclosure of your personal information (if any) to third parties for direct marketing purposes. If this law applies to you and you would like to make such a request, please submit your request in writing in compliance with the below section (Contact Us).
Last Updated: [November 6, 2019]
These CA Disclosures describe how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA).
When we use the term "personal information" in these CA Disclosures, we mean 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.
For the purposes of these Disclosures, personal information does not include:
In the last 12 months, we have collected the following categories of personal information:
|Category of Personal Information Collected||Collected||Categories of Sources|
|Identifiers, such as your name, address, phone number, email address, date of birth or other similar identifiers.||YES||
|California Customer Records (Cal. Civ. Code § 1798.80(e))||YES||
|Protected Classification Characteristics|
|Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)|
|Other Personal Information|
We collect personal information from and about you for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to 'How we use your information' and 'The information we collect' in our Privacy Statement.
We do not sell personal information and will not sell personal information unless we provide proper notice to consumers and, in the case of personal information collected prior to that notice, we obtain explicit consent for the sale of personal information relating to those individuals we previously interacted with.
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
|The Right to Know||
You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
The Right to Request Deletion
You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising these rights.
However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
To exercise your Right to Know and/or your Right to Deletion, please submit a request by:
We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Unless you have exercised your Right to Opt Out of Personal Information Sales, we may sell personal information to third parties for monetary or other valuable consideration. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties. Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at firstname.lastname@example.org.
At this time, we do not sell your Personal Information.
We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at [insert email] to inform us if you, or your minor child, are under the age of 16.
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.
If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to email@example.com.
Alternatively, inquiries may be addressed to:
175 Varick Street,
New York, New York 10014