This Policy Was Last Updated August 30, 2021
B. Third Parties.
C. Jurisdictional Issues.
D. Collection, Use and Disclosure of Personal Information.
Personal Information We May Collect
“Personal Information” is information that identifies someone, including EU and Swiss individuals, as a specific individual. In addition to Personal Information, Other Information (as defined below) may be collected in connection with the Platform; the collection, use and disclosure of Other Information is addressed separately below, under the “Other Information” heading.
We and our third-party service providers may collect the following Personal Information, including that of EU and Swiss individuals:
- Home address.
- Personal telephone number.
- Personal e-mail address.
- Social Security number.
- Individual Taxpayer Identification numbers.
- Personal bank account, credit card and debit card numbers.
- Date of birth.
- Other personally identifiable information about you and third parties that you may choose to disclose (including by authorizing third parties to disclose) to Company and/or its third-party service providers, including by completing profile forms, completing applications, questionnaires, or similar documents, communicating with customer service personnel, and otherwise interacting with Company and its third-party service providers.
Certain Personal Information is voluntary and not required to access or use the Platform; other Personal Information may be mandatory and required to access or use the Platform or certain portions of the Platform.
How We May Use Personal Information
We and our third-party service providers may use Personal Information, including that of EU and Swiss individuals:
- To respond to your inquiries and fulfill your requests, such as to send newsletters to you, process your applications, complete your commercial transactions, and otherwise operate the Platform-related products and services and the businesses of Company and its related legal entities.
- To send administrative information to you, including information regarding the Platform and changes to our terms, conditions, and policies.
- To facilitate business transactions.
- To allow you to send and receive messages and invitations to and from other individuals, through or in connection with the Platform, and to send and receive such messages and invitations on your behalf.
- To help us improve the customer experience, including by learning more about your preferences to help personalize your experience with us.
- To send marketing communications to you that we believe may be of interest to you unless you opt-out in accordance with the Choices and Access section below.
- For our business, administrative and informational purposes, including but not limited to quality assessment, data analysis, audits, developing and improving the Platform and new products and services, identifying usage trends and determining the effectiveness of our promotional campaigns.
- To protect the security or integrity of our businesses and Internet properties, including the Platform.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our related legal entities; (f) to protect our rights, privacy, safety, or property, or that of our related legal entities, service providers, members, you or others, including through credit-fraud protection and risk reduction; (g) at our discretion under emergency circumstances; or (h) to allow us to pursue available remedies or limit the damages that we may sustain.
How Personal Information May Be Disclosed
Personal Information, including that of EU and Swiss individuals, may be disclosed:
- To our third-party service providers that may provide services such as hosting of the Platform, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing, information and identity verification, credit checks, payment processing, and other similar services. Although we seek to restrict third-party service providers from using any Personal Information received from Company or through the Platform for any purpose other than providing services for Company and the Platform, please note that Company is not responsible for the privacy practices of any third parties, including any negligence or misconduct by any third parties that receive your payment card or other information.
- To identify you to anyone to whom you send messages or invitations through or in connection with the Platform, including messages and invitations that we may send on your behalf.
- To facilitate business transactions.
- By you, through messages, chats, message boards, forums, public profile pages, user directories, and blogs and other functionality with which you are able to share or post information and materials. Please note that any information and materials that you post or disclose using such functionality will become public information and may be available for other users of the Platform and the public to access, use, alter, manipulate, or disclose. We are not responsible for such access, use, alteration, manipulation, or disclosure. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, in connection with the Platform.
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to lawful requests, including requests for disclosures necessary to meet national security or law enforcement requirements, from public or government authorities, including public or government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our related legal entities; (f) to protect our rights, privacy, safety or property, or that of our related legal entities, service providers, members, you or others, including through credit-fraud protection and risk reduction; (g) at our discretion under emergency circumstances; or (h) to allow us to pursue available remedies or limit the damages that we may sustain.
E. Collection, Use, Disclosure of Other Information.
Other Information We May Collect
“Other Information” is any information that does not reveal a person’s specific identity, such as:
- Browser information.
- Server log files.
- Statistics concerning messages sent or received through the Platform, such as the length of such messages, the IP Addresses involved and other technical parameters.
- Information collected through cookies, pixel tags, and other technologies.
- Browsing analytics.
- Demographic information.
- Aggregated information.
- Physical location data.
- Information relating to a corporation, partnership, or other business entity.
How We May Collect Other Information
We and our third-party service providers may collect Other Information in a variety of ways, including:
- Through your device: Certain information is collected automatically through your device, such as your operating system name and version, device manufacturer and model, device identifiers, language, and the name and version of the software application you are using.
- Through server log files: Your “IP Address” is a number that is automatically assigned to the device that you are using by your Internet Service Provider (“ISP”). An IP Address is identified and logged automatically in our server log files whenever a user uses the Platform, along with the time of the use and the pages or areas visited within the Platform. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We and our third-party service providers use IP Addresses for purposes such as helping to calculate usage levels of the Platform, diagnose server problems and administer the Platform.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) and other similar technologies may be used in connection with some pages and areas of the Platform and HTML-formatted e-mail messages to, among other things, track the actions of users of the Platform and e-mail recipients, measure the success of our marketing campaigns and compile statistics about usage and response rates of the Platform.
- Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower, or Wi-Fi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
- From you: We may collect demographic information such as, for example, your age, occupation, and family status, as well as other information when you voluntarily provide such information to us. We may also collect such information about you from third parties. Unless combined with Personal Information, this information does not personally identify you or any other user of the Platform.
- By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Platform. For example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code.
How We May Use and Disclose Other Information
Because Other Information does not personally identify you, we may use and disclose Other Information for any purpose. In some instances, we may combine Other Information with Personal Information (such as combining your zip code with your name). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information if it is so combined.
F. Third Party Advertisers.
We may use third-party advertising companies to serve ads when you visit the Platform. Please note that these companies may use information about your visit to the Platform to provide ads about goods and services that may be of interest to you. While serving ads to the Platform, these companies may place or recognize a unique cookie on your browser. If you would like more information about this practice, and to know your choices about not having this information used by these companies, please visit http://networkadvertising.org/optout_nonppii.asp.
G. Social Plugins
H. Do Not Track Signals.
We seek to use within Company reasonable organizational, technical, and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system is guaranteed to be 100% secure. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that are generally non-negotiable; accordingly, although we seek to conduct reasonable due diligence on such service providers, we may be unable to impose contractual obligations on them with respect to the measures they use to protect Personal Information. We are not responsible for the data security measures of any third parties.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us via Company’s Contact Page.
J. Choices and Access
We give you many choices regarding our use and disclosure of your Personal Information, including that of EU and Swiss individuals, for marketing purposes. You may opt-out from:
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of our sharing of Personal Information with related legal entities for their marketing purposes, as described above, we will not be able to remove your Personal Information from the databases of any such related legal entities with which we have already shared your Personal Information (i.e., to which we have already provided your Personal Information as of the date that we implement your opt-out request). Please also note that if you do opt-out of receiving marketing-related e-mails from us, we may still send to you administrative messages, messages related to the fulfillment of our products and services, and messages that are sent to you in your capacity as a representative of your business entity; you cannot opt-out from receiving such messages.
How You Can Access Your Personal Information
If you would like to review or update your Personal Information, including that of EU and Swiss individuals, that has been previously provided to us, you may do so by logging into your account within the Platform, or, for certain Personal Information that is not reviewable through the Platform, you may contact us via Company’s Contact Page.
We will try to comply with your request to update your Personal Information as soon as reasonably practicable. We are not responsible for changing information in the databases of third parties with whom we have already shared your Personal Information.
K. No Use of the Platform by Minors.
The Platform is not directed to individuals under the age of thirteen (13), nor are such individuals permitted to use the Platform; accordingly, we request that such individuals do not provide Personal Information in connection with the Platform. If you are the parent or guardian of such an individual who has disclosed Personal Information to us in connection with the Platform, please contact us via Company’s Contact Page, and we will exercise commercially reasonable efforts to remove such information from our databases and storage systems; we are not liable, however, for any consequences of such information, including any delay or failure to remove such information.
L. Retention Period.
M. Your California Privacy Rights
California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding Company’s disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please write us or call:
Call: 1.773.233.5811 Email: email@example.com