Last Updated and Effective as of: September 21, 2022
Your provision of your personal information to us is completely voluntary. “Personal information” is information that can specifically identify you. We do not collect personal information unless you submit that information to us. Categories of personal information we may collect include:
Identity Data, which includes name or other similar identifiers.
Contact Data, which includes address, email address and telephone numbers.
Additionally, we may also collect certain others types of information that, along with Identity Data and Contact Data, may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:
Financial Data, which includes credit card, debit card or other payment card details.
Transaction Data, which includes details about payments to and from you.
Technical Data, which includes internet protocol (IP) address, location data, your login data, and device and browser information.
Profile Data, which includes your username and password, avatar photograph (if you upload one) and other info you share with us on our Website.
Usage Data, which includes information about how you use our Website and advertising we serve on those sites.
Marketing and Communications Data, which includes your preferences in receiving marketing from us
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your information by registering or contacting us. This includes information you provide when you:
create an account on our website;
subscribe to our service or publications;
purchase product(s) on our website(s)
request marketing to be sent to you; or
give us feedback.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data and Usage Data about you. Some of the ways in which we or our website may collect are further described below:
Interest-Based Advertising: We may engage third-party vendors to use your information in connection with their own information to deliver targeted advertising to you when you visit our website or other websites. Cookies, described above, may be used in this process. For example, if you are searching for information on a particular product, our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising is called “behavioral advertising”. We believe that such advertising is helpful because you will see ads that are relevant to your interests. However, if you would like to opt-out of these interest-based advertisements, please see the Opt-Out section below.
Clickstream Data: As you use the Internet, a trail of electronic information is left at each website you visit. This information, sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. For example, clickstream data can tell the type of computer and browsing software you use and the address of the website from which you linked to the website. The website may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our website, how visitors navigate throughout the Website and how we may tailor our website to better meet the needs of visitors. This information often will be used to improve our website and our services. Any collection or use of clickstream data will be anonymous and aggregated and will not intentionally contain any personal information.
THIRD-PARTY LINKS AND SOCIAL NETWORKING SERVICES
The Website may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.
You should be aware that information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.
We have put in place appropriate security measures to prevent information about you from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed; however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We have put in place procedures to deal with any suspected data breach that will affect you and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.
PROVISION OF PERSONAL DATA AND FAILURE TO PROVIDE PERSONAL DATA
Where we need to collect personal data 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 our services). In this case, we will not be able to provide services to you.
LEGAL BASIS FOR OUR PROCESSING OF YOUR PERSONAL DATA
Below are the types of lawful basis that we will rely on to process your personal data:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at firstname.lastname@example.org
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
WITHDRAWING YOUR CONSENT
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at firstname.lastname@example.org.
USE OF YOUR PERSONAL DATA FOR MARKETING PURPOSES
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
To see how you can opt out of marketing communications, please see the section titled “Opt-Out” found at the bottom of all of our email communications.
OPTING OUT OF MESSAGES FROM US
To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at email@example.com. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of the Website may no longer be available to you.
OPTING OUT OF COOKIES
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge.
DATA RELATING TO CHILDREN
Our Website is designed for those 18 years of age and older. We do not knowingly collect information from anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.
CROSS BORDER TRANSFERS
If you are a California resident this section applies to you. Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personally identifiable information, such as name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us at firstname.lastname@example.org. If you do not want your personally identifying information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at email@example.com.