EFFECTIVE DATE: June 1, 2020
By visiting the Sites, or using any of our Apps, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Apps, and any dispute over privacy, is subject to this Policy.
The Information We Collect About You
We collect information about you directly from you and automatically through your use of our Site or Apps.
Information We Collect Directly from You. The information we collect from you depends on how you use our Sites and Apps.
Information We Collect Automatically. We automatically collect information about your use of our Site and Apps through cookies, web beacons, and other technologies, including technologies designed for mobile apps. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. The information we automatically collect includes your:
Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
How We Share Your Information
We may share your information, including personal information, as follows:
We also disclose information in the following circumstances:
may share certain of your personal information with lenders, auditors, and advisors, including attorneys and consultants.
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites and Apps, while others are used to enable a faster log-in process or to allow us to track your activities at our Sites and Apps.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help tool on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable cookies will be able to browse certain areas of the Sites, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your device’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Sites and Apps to, among other things, track the activities of Sites visitors and Apps users, help us manage content, and compile statistics about Sites and Apps usage. We and our service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests.
Site visitors may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising online. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Our Site and Apps may contain links to non-affiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those non-affiliated websites. We are not responsible for the information practices of such websites.
Security of Your Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password and devices by, among other things, signing off after using a shared device, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Marketing Communications and Your Choices
We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
Children Under 13
Our Site and Apps are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
Important Additional Privacy Information for California Residents
Because we collect and process personal information in the context of our business relationship with you or your employer, California residents’ rights under the California Consumer Privacy Act (“CCPA”) are limited to the right to opt-out and the right to non-discrimination.
Right to Opt-out of Sale of Personal Information. The CCPA defines “sale” of personal information very broadly, including as “sales” disclosure of personal information in exchange for receiving anything of value, which includes quite a few situations that are not commonly understood to be “sales.” Under this very broad definition, we may “sell” personal information due to our use of website advertising cookies and other tracking devices used for online interest-based advertising. If you would like to opt-out of interest-based advertising as provided by our online advertising providers, please see the Ad Networks section above or adjust your web browser’s settings to reject cookies.
Right to Non-Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.
If you have questions about the privacy aspects of our Site and Apps or would like to make a complaint, please contact us at email@example.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and Apps. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and Apps.