Effective: July 1, 2019
Notice Last Updated: January 1, 2021
This Policy applies to information we collect from or about you: (1) when you access or use our mobile applications (“Applications”), websites (“Websites”), or products and/or services (“Products”); (2) when you communicate with us in any manner, including by email, telephone, and/or in person; and (3) from third party sources.
Please read this Policy carefully. The practices described herein are subject to the laws in the places in which we operate.
BY ACCESSING AND/OR USING OUR APPLICATIONS, WEBSITES, AND/OR PRODUCTS, OR BY COMMUNICATING WITH US IN ANY MANNER, YOU REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY.
Depending upon how you interact with our Websites, Applications, or Products, how you communicate with us, or our interactions with third parties, we may collect the following categories of information from and about you:
We collect your information in three ways:
Directly from you when you access or use our Applications, Websites, or Products, or when you communicate with us in any manner, including but not limited to:
Automatically when you access or use our Applications, Websites, or Products, or when you communicate with us, including but not limited to:
From third parties, including but not limited to:
We use the information outlined in What Type of Information Do We Collect About You for a variety of business and commercial purposes, including but not limited to:
We do not sell your personal information. We may, however, disclose or share information referenced in What Type of Information Do We Collect About You with others for a variety of business and commercial purposes, including:
Our Applications and Websites may contain links to third party websites and services. Please note that these links are provided for your convenience and information, and the websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review. This Privacy Notice applies to our Applications and Websites only, and we do not accept any responsibility or liability for the policies or practices of any third parties.
Our Websites and Applications may, from time to time, collect information about your online activities, over time and across our different Websites and Applications. When you use our Websites and Applications, third parties may also collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Websites do not currently change the way they operate based upon detection of a “Do Not Track” or similar signal.
Our Applications, Websites, and/or Products may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook or Twitter. When you do, we may collect additional information from or about you, such as your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform. Please be advised that social media platforms may also collect information from you. We do not have control over the collection, use and sharing practices of social media platforms. We therefore encourage you to review their usage and disclosure policies and practices, including their data security practices, before using the social media platforms.
Although no system can guarantee the complete security of your information, we take all commercially reasonable steps to ensure your information is protected in alignment with all applicable laws and regulations, as appropriate to the sensitivity of your information.
We keep your information for as long as necessary in accordance with the purpose for which it was collected, our business needs, and our legal and regulatory obligations. If we dispose of your information, we will do so in a way that is secure and appropriate to nature of the information subject to disposal.
Below is an overview of the types of cookies and related technology we deploy, and your choices.
Flash Cookies. Certain features of our Websites and Applications may use locally stored objects called flash cookies to collect and store information about your preferences and navigation to, from and on our Applications and Websites. We also may include cookies to provide aggregate reporting. Some of our Websites and Applications may allow Adobe to set and enable special cookies that are necessary to deliver video content for Adobe Flash Player. You cannot remove flash cookies simply by changing your browser settings. If you would like to limit the websites that can store information in flash cookies on your device, you must visit the Adobe website: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
Beacons. Our Websites and e-mails may contain small electronic files known as beacons (also referred to as web beacons, clear GIFs, pixel tags and single-pixel GIFs) that permit us to, for example, to count users who have visited those pages or opened an e-mail and for other website-related statistics. Beacons in e-mail marketing campaigns allow us to track your responses and your interests in our content, offerings and web pages. You may use the tools in your device to disable these technologies as well.
We provide you the ability to exercise certain controls and choices regarding our collection, use, storage, and sharing of your information. Please note that for some of these rights, such as the Right to Know and Right to Delete, we will verify your identity before we respond to your request. To verify your identity, we will generally match the identifying information provided in your request with the information we have on file about you. Depending on the sensitivity of the personal information requested to be deleted, we may also utilize more stringent verification methods to verify your identity, including but not limited to requesting additional information from you and/or requiring you to sign a declaration under penalty of perjury.
Our Applications, Websites, and Products are not intended for children under the age of 18. This includes any links to other websites that we provide for our convenience. We don’t knowingly collect the information of children for any reason.
Our Applications, Websites, and Products are hosted and offered in the United States of America (US), and are subject to US federal, state, and local law. If you are accessing the Applications, Websites, or Products from another country, please be advised that you may be transferring your information to us in the US, and you consent to that transfer and use of your information in accordance with this Policy. You also agree to abide by the applicable laws of applicable US federal, state, and local laws concerning your use of the Applications, Websites, and Products, and your agreements with us. Any persons accessing our Applications, Websites, or Products from any jurisdiction with laws or regulations governing the use of the Internet, including the collection, use, or disclosure of information, different from those of the jurisdictions mentioned above may only use the Applications, Websites, or Products in a manner lawful in their jurisdiction. If your use of the Applications, Websites, or Products would be unlawful in your jurisdiction, you may not use the Applications, Websites, or Products.
We may change this Policy from time to time. Any and all changes will be reflected on this page, and where appropriate provided in person or by another electronic method. The effective date will be stated at the top of this Policy. You should regularly check this page for any changes to this Privacy Notice.
YOUR CONTINUED USE, ACCESS, OR INTERACTION WITH THE APPLICATIONS, WEBSITES, OR PRODUCTS, OR YOUR CONTINUED COMMUNICATIONS WITH US AFTER THE UPDATED POLICY HAS BEEN POSTED WILL REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY.