4.
HOW LONG DO WE KEEP YOUR
INFORMATION?
In
Short: We
keep your information for as
long as necessary to fulfill
the purposes outlined in this
privacy notice unless otherwise
required by law.
We
will only keep your personal
information for as long as it is
necessary for the purposes set
out in this privacy notice,
unless a longer retention period
is required or permitted by law
(such as tax, accounting, or
other legal requirements).
When
we have no ongoing legitimate
business need to process your
personal information, we will
either delete or anonymize
such information, or, if this is
not possible (for example,
because your personal
information has been stored in
backup archives), then we will
securely store your personal
information and isolate it from
any further processing until
deletion is possible.
5.
HOW DO WE KEEP YOUR
INFORMATION SAFE?
In
Short: We
aim to protect your personal
information through a system of
organizational
and technical security
measures.
We
have implemented appropriate and
reasonable technical and organizational
security measures designed to
protect the security of any
personal information we process.
However, despite our safeguards
and efforts to secure your
information, no electronic
transmission over the Internet
or information storage
technology can be guaranteed to
be 100% secure, so we cannot
promise or guarantee that
hackers, cybercriminals, or
other unauthorized
third parties will not be able
to defeat our security and
improperly collect, access,
steal, or modify your
information. Although we will do
our best to protect your
personal information,
transmission of personal
information to and from our
Services is at your own risk.
You should only access the
Services within a secure
environment.
6.
WHAT ARE YOUR PRIVACY
RIGHTS?
In
Short: You
may review, change, or
terminate your account at any
time.
Withdrawing
your consent: If
we are relying on your consent
to process your personal
information,
which may be express and/or
implied consent depending on the
applicable law,
you have the right to withdraw
your consent at any time. You
can withdraw your consent at any
time by contacting us by using
the contact details provided in
the section "HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?"
below.
However,
please note that this will not
affect the lawfulness of the
processing before its withdrawal
nor,
when applicable law allows,
will it affect the processing of
your personal information
conducted in reliance on lawful
processing grounds other than
consent.
7.
CONTROLS FOR DO-NOT-TRACK
FEATURES
Most
web browsers and some mobile
operating systems and mobile
applications include a
Do-Not-Track ("DNT")
feature or setting you can
activate to signal your privacy
preference not to have data
about your online browsing
activities monitored and
collected. At this stage no
uniform technology standard for
recognizing
and implementing DNT signals has
been finalized.
As such, we do not currently
respond to DNT browser signals
or any other mechanism that
automatically communicates your
choice not to be tracked online.
If a standard for online
tracking is adopted that we must
follow in the future, we will
inform you about that practice
in a revised version of this
privacy notice.
8.
DO CALIFORNIA RESIDENTS HAVE
SPECIFIC PRIVACY RIGHTS?
In
Short: Yes,
if you are a resident of
California, you are granted
specific rights regarding
access to your personal
information.
California
Civil Code Section 1798.83, also
known as the "Shine
The Light"
law, permits our users who are
California residents to request
and obtain from us, once a year
and free of charge, information
about categories of personal
information (if any) we
disclosed to third parties for
direct marketing purposes and
the names and addresses of all
third parties with which we
shared personal information in
the immediately preceding
calendar year. If you are a
California resident and would
like to make such a request,
please submit your request in
writing to us using the contact
information provided below.
If
you are under 18 years of age,
reside in California, and have a
registered account with
Services, you have the right to
request removal of unwanted data
that you publicly post on the
Services. To request removal of
such data, please contact us
using the contact information
provided below and include the
email address associated with
your account and a statement
that you reside in California.
We will make sure the data is
not publicly displayed on the
Services, but please be aware
that the data may not be
completely or comprehensively
removed from all our systems
(e.g.,
backups, etc.).
CCPA
Privacy Notice
The
California Code of
Regulations defines a "resident"
as:
(1)
every individual who is in the
State of California for other
than a temporary or transitory
purpose and
(2)
every individual who is
domiciled in the State of
California who is outside the
State of California for a
temporary or transitory purpose
All
other individuals are defined as
"non-residents."
If
this definition of "resident"
applies to you, we must adhere
to certain rights and
obligations regarding your
personal information.
What
categories of personal
information do we collect?
We
have collected the following
categories of personal
information in the past twelve
(12) months:
| Category |
Examples |
Collected |
A.
Identifiers
|
Contact
details, such as real name,
alias, postal address,
telephone or mobile contact
number, unique personal
identifier, online
identifier, Internet
Protocol address, email
address, and account name
|
NO
|
B.
Personal information
categories listed in the
California Customer Records
statute
|
Name,
contact information,
education, employment,
employment history, and
financial information
|
NO
|
C.
Protected classification
characteristics under
California or federal law
|
Gender
and date of birth
|
NO
|
D.
Commercial information
|
Transaction
information, purchase
history, financial details,
and payment information
|
NO
|
E.
Biometric information
|
Fingerprints
and voiceprints
|
NO
|
F.
Internet or other similar
network activity
|
Browsing
history, search history,
online behavior,
interest data, and
interactions with our and
other websites,
applications, systems, and
advertisements
|
NO
|
G.
Geolocation data
|
Device
location
|
NO
|
H.
Audio, electronic, visual,
thermal, olfactory, or
similar information
|
Images
and audio, video or call
recordings created in
connection with our business
activities
|
NO
|
I.
Professional or
employment-related
information
|
Business
contact details in order to
provide you our Services at
a business level or job
title, work history, and
professional qualifications
if you apply for a job with
us
|
NO
|
J.
Education Information
|
Student
records and directory
information
|
NO
|
K.
Inferences drawn from other
personal information
|
Inferences
drawn from any of the
collected personal
information listed above to
create a profile or summary
about, for example, an
individual’s preferences and
characteristics
|
NO
|
| L.
Sensitive Personal Information |
|
NO
|
We
may also collect other personal
information outside of these
categories through instances
where you interact with us in
person, online, or by phone or
mail in the context of:
- Receiving
help through our customer
support channels;
- Participation
in customer surveys or
contests; and
- Facilitation
in the delivery of our
Services and to respond to
your inquiries.
How
do we use and share your
personal information?
More
information about our data
collection and sharing
practices can be found in
this privacy notice.
You
may contact us
or
by referring to the contact
details at the bottom of this
document.
If
you are using an authorized
agent to exercise your right to
opt out we may deny a request
if the authorized
agent does not submit proof
that they have been validly authorized
to act on your behalf.
Will
your information be shared
with anyone else?
We
may disclose your personal
information with our service
providers pursuant to a written
contract between us and each
service provider. Each service
provider is a for-profit entity
that processes the information
on our behalf, following the
same strict privacy protection
obligations mandated by the
CCPA.
We
may use your personal
information for our own
business purposes, such as for
undertaking internal research
for technological development
and demonstration. This is not
considered to be "selling"
of your personal information.
__________ has
not disclosed, sold, or shared
any personal information to
third parties for a business or
commercial purpose in the
preceding twelve (12) months. __________ will
not sell or share personal
information in the future
belonging to website visitors,
users, and other consumers.
Your
rights with respect to your
personal data
Right
to request deletion of the
data — Request to delete
You
can ask for the deletion of
your personal information. If
you ask us to delete your
personal information, we will
respect your request and delete
your personal information,
subject to certain exceptions
provided by law, such as (but
not limited to) the exercise by
another consumer of his or her
right to free speech, our
compliance requirements
resulting from a legal
obligation, or any processing
that may be required to protect
against illegal activities.
Right
to be informed — Request to
know
Depending
on the circumstances, you have
a right to know:
- whether
we collect and use your
personal information;
- the
categories of personal
information that we collect;
- the
purposes for which the
collected personal information
is used;
- whether
we sell or share personal
information to third parties;
- the
categories of personal
information that we sold,
shared, or disclosed for a
business purpose;
- the
categories of third parties to
whom the personal information
was sold, shared, or disclosed
for a business purpose;
- the
business or commercial purpose
for collecting, selling, or
sharing personal information;
and
- the
specific pieces of personal
information we collected about
you.
In
accordance with applicable law,
we are not obligated to provide
or delete consumer information
that is de-identified in
response to a consumer request
or to re-identify individual
data to verify a consumer
request.
Right
to Non-Discrimination for the
Exercise of a Consumer’s
Privacy Rights
We
will not discriminate against
you if you exercise your
privacy rights.
Right
to Limit Use and Disclosure of
Sensitive Personal Information
We
do not process consumer's
sensitive personal information.
Verification
process
Upon
receiving your request, we will
need to verify your identity to
determine you are the same
person about whom we have the
information in our system.
These verification efforts
require us to ask you to
provide information so that we
can match it with information
you have previously provided
us. For instance, depending on
the type of request you submit,
we may ask you to provide
certain information so that we
can match the information you
provide with the information we
already have on file, or we may
contact you through a
communication method (e.g.,
phone or email) that you have
previously provided to us. We
may also use other verification
methods as the circumstances
dictate.
We
will only use personal
information provided in your
request to verify your identity
or authority to make the
request. To the extent
possible, we will avoid
requesting additional
information from you for the
purposes of verification.
However, if we cannot verify
your identity from the
information already maintained
by us, we may request that you
provide additional information
for the purposes of verifying
your identity and for security
or fraud-prevention purposes.
We will delete such
additionally provided
information as soon as we
finish verifying you.
Other
privacy rights
- You
may object to the processing
of your personal information.
- You
may request correction of your
personal data if it is
incorrect or no longer
relevant, or ask to restrict
the processing of the
information.
- You
can designate an authorized
agent to make a request under
the CCPA on your behalf. We
may deny a request from an authorized
agent that does not submit
proof that they have been
validly authorized
to act on your behalf in
accordance with the CCPA.
- You
may request to opt out from
future selling or sharing of
your personal information to
third parties. Upon receiving
an opt-out request, we will
act upon the request as soon
as feasibly possible, but no
later than fifteen (15) days
from the date of the request
submission.
To
exercise these rights, you can
contact us
or
by referring to the contact
details at the bottom of this
document. If you have a complaint
about how we handle your data, we
would like to hear from you.
9.
DO VIRGINIA RESIDENTS HAVE
SPECIFIC PRIVACY RIGHTS?
In
Short: Yes,
if you are a resident of
Virginia, you may be granted
specific rights regarding
access to and use of your
personal information.
Virginia
CDPA Privacy Notice
Under
the Virginia Consumer Data
Protection Act (CDPA):
"Consumer"
means a natural person who is a
resident of the Commonwealth
acting only in an individual or
household context. It does not
include a natural person acting
in a commercial or employment
context.
"Personal
data"
means any information that is
linked or reasonably linkable to
an identified or identifiable
natural person. "Personal
data"
does not include de-identified
data or publicly available
information.
"Sale
of personal data"
means the exchange of personal
data for monetary consideration.
If
this definition "consumer"
applies to you, we must adhere
to certain rights and
obligations regarding your
personal data.
The
information we collect, use, and
disclose about you will vary
depending on how you interact
with __________
and our Services. To find out
more, please visit the following
links:
Your
rights with respect to your
personal data
- Right
to be informed whether or not
we are processing your personal
data
- Right
to access your personal data
- Right
to correct inaccuracies in your
personal data
- Right
to request deletion of your
personal data
- Right
to obtain a copy of the
personal data you previously
shared with us
- Right
to opt out of the processing of
your personal data if it is
used for targeted advertising,
the sale of personal data, or
profiling in furtherance of
decisions that produce legal or
similarly significant effects ("profiling")
__________
has not sold any personal data to
third parties for business or
commercial purposes. __________
will not sell personal data in
the future belonging to website
visitors, users, and other
consumers.
Exercise
your rights provided under the
Virginia CDPA
More
information about our data
collection and sharing practices
can be found in this privacy
notice.
You
may contact us by email at __________,
by
submitting a
data
subject access request,
or by referring to the contact
details at the bottom of this
document.
If
you are using an authorized
agent to exercise your rights,
we may deny a request if the authorized
agent does not submit proof that
they have been validly authorized
to act on your behalf.
Verification
process
We
may request that you provide
additional information
reasonably necessary to verify
you and your consumer's request.
If you submit the request
through an authorized
agent, we may need to collect
additional information to verify
your identity before processing
your request.
Upon
receiving your request, we will
respond without undue delay, but
in all cases, within forty-five
(45) days of receipt. The
response period may be extended
once by forty-five (45)
additional days when reasonably
necessary. We will inform you of
any such extension within the
initial 45-day response period,
together with the reason for the
extension.
Right
to appeal
If
we decline to take action
regarding your request, we will
inform you of our decision and
reasoning behind it. If
you wish to appeal our decision,
please email us at
__________
.
Within sixty (60) days of
receipt of an appeal, we will
inform you in writing of any
action taken or not taken in
response to the appeal,
including a written explanation
of the reasons for the
decisions. If your appeal if
denied, you may contact
the
Attorney
General to submit a complaint.
10.
DO WE MAKE UPDATES TO THIS
NOTICE?
In
Short: Yes, we
will update this notice as
necessary to stay compliant
with relevant laws.
We
may update this privacy notice
from time to time. The updated
version will be indicated by an
updated "Revised"
date and the updated version
will be effective as soon as it
is accessible. If we make
material changes to this
privacy notice, we may notify
you either by prominently
posting a notice of such
changes or by directly sending
you a notification. We
encourage you to review this
privacy notice frequently to be
informed of how we are
protecting your information.
11.
HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
If
you have questions or comments
about this notice, you may email
us at __________
or
contact us by post at:
__________
__________
__________
12.
HOW CAN YOU REVIEW, UPDATE,
OR DELETE THE DATA WE
COLLECT FROM YOU?
Based
on the applicable laws of your
country, you may have the right
to request access to the
personal information we collect
from you, change that
information, or delete it.
To
request to review, update, or
delete your personal
information, please fill
out and submit a data subject
access request
.
