Last updated August 28, 2022
This privacy notice for us, describes how and why we
might collect, store, use, and/or share
(“process”) your information when you use
our services (“Services”), such as when
you visit our website
or any website of ours that links to this privacy
notice. Engage with us in other related ways,
including any sales, marketing, or event. Questions or
concerns? Reading this privacy notice will help you
understand your privacy rights and choices. If you do
not agree with our policies and practices, please do
not use our Services. If you still have any questions
or concerns, please contact us
SUMMARY OF KEY POINTS
This summary provides key points from our privacy
notice.
What personal information do we process? When you
visit, use, or navigate our Services, we may process
personal information depending on how you interact
with us and the Services, the choices you make, and
the products and features you use.
Do we process any sensitive personal information? We
do not process sensitive personal information.
Do we receive any information from third parties? We
do not receive any information from third parties.
How do we process your information? We process your
information to provide, improve, and administer our
Services, communicate with you, for security and fraud
prevention, and to comply with law. We may also
process your information for other purposes with your
consent. We process your information only when we have
a valid legal reason to do so.
In what situations and with which parties do we share
personal information? We may share information in
specific situations and with specific third
parties.
How do we keep your information safe? We have
organizational and technical processes and procedures
in place to protect your personal information.
However, 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.
What are your rights? Depending on where you are
located geographically, the applicable privacy law may
mean you have certain rights regarding your personal
information.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING
TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you
provide to us.
We collect personal information that you voluntarily
provide to us when you express an interest in
obtaining information about us or our products and
Services, when you participate in activities on the
Services, or otherwise when you contact us.
Personal Information Provided by You. The personal
information that we collect depends on the context of
your interactions with us and the Services, the
choices you make, and the products and features you
use. The personal information we collect may include
the following:
names
email addresses
Sensitive Information. We do not process sensitive
information.
All personal information that you provide to us must
be true, complete, and accurate, and you must notify
us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet
Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you
visit our Services.
We automatically collect certain information when you
visit, use, or navigate the Services. This information
does not reveal your specific identity (like your name
or contact information) but may include device and
usage information, such as your IP address, browser
and device characteristics, operating system, language
preferences, referring URLs, device name, country,
location, information about how and when you use our
Services, and other technical information. This
information is primarily needed to maintain the
security and operation of our Services, and for our
internal analytics and reporting purposes.
Like many businesses, we also collect information
through cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is
service-related, diagnostic, usage, and performance
information our servers automatically collect when you
access or use our Services and which we record in log
files. Depending on how you interact with us, this log
data may include your IP address, device information,
browser type, and settings and information about your
activity in the Services (such as the date/time stamps
associated with your usage, pages and files viewed,
searches, and other actions you take such as which
features you use), device event information (such as
system activity, error reports (sometimes called
“crash dumps”), and hardware settings).
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide,
improve, and administer our Services, communicate with
you, for security and fraud prevention, and to comply
with law. We may also process your information for
other purposes with your consent.
We process your personal information for a variety of
reasons, depending on how you interact with our
Services, including:
To request feedback. We may process your information
when necessary to request feedback and to contact you
about your use of our Services.
To identify usage trends. We may process information
about how you use our Services to better understand
how they are being used so we can improve them.
To determine the effectiveness of our marketing and
promotional campaigns. We may process your information
to better understand how to provide marketing and
promotional campaigns that are most relevant to
you.
To save or protect an individual’s vital
interest. We may process your information when
necessary to save or protect an individual’s vital
interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In Short: We only process your personal information
when we believe it is necessary and we have a valid
legal reason (i.e., legal basis) to do so under
applicable law, like with your consent, to comply with
laws, to provide you with services to enter into or
fulfill our contractual obligations, to protect your
rights, or to fulfill our legitimate business
interests.
If you are located in the EU or UK, this section
applies to you.
The General Data Protection Regulation (GDPR) and UK
GDPR require us to explain the valid legal bases we
rely on in order to process your personal information.
As such, we may rely on the following legal bases to
process your personal information:
Consent. We may process your information if you have
given us permission (i.e., consent) to use your
personal information for a specific purpose. You can
withdraw your consent at any time.
Legitimate Interests. We may process your information
when we believe it is reasonably necessary to achieve
our legitimate business interests and those interests
do not outweigh your interests and fundamental rights
and freedoms. For example, we may process your
personal information for some of the purposes
described in order to:
Analyze how our services are used so we can improve
them to engage and retain users
Support our marketing activities
Understand how our users use our products and services
so we can improve user experience
Legal Obligations. We may process your information
where we believe it is necessary for compliance with
our legal obligations, such as to cooperate with a law
enforcement body or regulatory agency, exercise or
defend our legal rights, or disclose your information
as evidence in litigation in which we are involved.
Vital Interests. We may process your information where
we believe it is necessary to protect your vital
interests or the vital interests of a third party,
such as situations involving potential threats to the
safety of any person.
If you are located in Canada, this section applies to
you.
We may process your information if you have given us
specific permission (i.e., express consent) to use
your personal information for a specific purpose, or
in situations where your permission can be inferred
(i.e., implied consent). You can withdraw your consent
at any time.
In some exceptional cases, we may be legally permitted
under applicable law to process your information
without your consent, including, for example:
If collection is clearly in the interests of an
individual and consent cannot be obtained in a timely
way
For investigations and fraud detection and
prevention
For business transactions provided certain conditions
are met
If it is contained in a witness statement and the
collection is necessary to assess, process, or settle
an insurance claim
For identifying injured, ill, or deceased persons and
communicating with next of kin
If we have reasonable grounds to believe an individual
has been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with
consent would compromise the availability or the
accuracy of the information and the collection is
reasonable for purposes related to investigating a
breach of an agreement or a contravention of the laws
of Canada or a province
If disclosure is required to comply with a subpoena,
warrant, court order, or rules of the court relating
to the production of records
If it was produced by an individual in the course of
their employment, business, or profession and the
collection is consistent with the purposes for which
the information was produced
If the collection is solely for journalistic,
artistic, or literary purposes
If the information is publicly available and is
specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We may share information in specific
situations described in this section and/or with the
following third parties.
We may need to share your personal information in the
following situations:
Business Transfers. We may share or transfer your
information in connection with, or during negotiations
of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to
another company.
5. DO WE USE COOKIES AND OTHER TRACKING
TECHNOLOGIES?
In Short: We may use cookies and other tracking
technologies to collect and store your information.
We may use cookies and similar tracking technologies
(like web beacons and pixels) to access or store
information. Specific information about how we use
such technologies and how you can refuse certain
cookies is set out in our Cookie Notice.
6. 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). No purpose
in this notice will require us keeping your personal
information for longer than 90 days.
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.
7. 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.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or
market to children under 18 years of age.
We do not knowingly solicit data from or market to
children under 18 years of age. By using the Services,
you represent that you are at least 18 or that you are
the parent or guardian of such a minor and consent to
such minor dependent’s use of the Services. If we
learn that personal information from users less than
18 years of age has been collected, we will deactivate
the account and take reasonable measures to promptly
delete such data from our records. If you become aware
of any data we may have collected from children under
age 18, please contact us
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European
Economic Area (EEA), United Kingdom (UK), and Canada,
you have rights that allow you greater access to and
control over your personal information. You may
review, change, or terminate your account at any
time.
In some regions (like the EEA, UK, and Canada), you
have certain rights under applicable data protection
laws. These may include the right (i) to request
access and obtain a copy of your personal information,
(ii) to request rectification or erasure; (iii) to
restrict the processing of your personal information;
and (iv) if applicable, to data portability. In
certain circumstances, you may also have the right to
object to the processing of your personal information.
You can make such a request by contacting us by using
the contact details provided in the section “HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
We will consider and act upon any request in
accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we
are unlawfully processing your personal information,
you also have the right to complain to your local data
protection supervisory authority. You can find their
contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details
for the data protection authorities are available
here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
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.
Cookies and similar technologies: Most Web browsers
are set to accept cookies by default. If you prefer,
you can usually choose to set your browser to remove
cookies and to reject cookies. If you choose to remove
cookies or reject cookies, this could affect certain
features or services of our Services. To opt out of
interest-based advertising by advertisers on our
Services visit http://www.aboutads.info/choices/.
If you have questions or comments about your privacy
rights, you may email us.
10. 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.
11. 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
– YES
B. Personal information categories listed in the
California Customer Records statute
Name, contact information, education, employment,
employment history, and financial information
– YES
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
– YES
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
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.
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.
We have not disclosed or sold any personal information
to third parties for a business or commercial purpose
in the preceding twelve (12) months. We will not sell
personal information in the future belonging to
website visitors, users, and other consumers.
Your rights with respect to your personal data
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.
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 your personal information to third
parties;
the categories of personal information that we sold or
disclosed for a business purpose;
the categories of third parties to whom the personal
information was sold or disclosed for a business
purpose; and
the business or commercial purpose for collecting or
selling personal information.
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.
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 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 by
email
by visiting
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.
Metrics
Our metrics for all CCPA requests received for the
previous calendar year can be found.
12. 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.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice,
you may email us.
14. 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.