Privacy and Information Security Policy
WHAT PERSONALLY IDENTIFIABLE INFORMATION DO WE OBTAIN FROM YOU? WHEN DO WE OBTAIN SUCH INFORMATION?
If, upon visiting our Website, your use is limited to browsing our informational content, we will not require that you provide us with any personally identifiable information. However, we may request personal information from you at other times. For example:
- If you enroll retain the services of the Company or sign up for a User Account through our Website, we may ask that you provide us with certain personal information, including your name, credit card number, expiration date, e-mail address, mailing address and telephone number.
- If you post to our discussion forums, we will ask that you provide us with your name, e-mail address and password.
- If you want to enter any sweepstakes, contests or promotions sponsored by us or by one of our business partners, we will need your name, e-mail address and other information as may be required by the rules of the specific contest.
- If you choose to participate in a customer survey conducted by us or by one of our business partners, we may ask for your name, e-mail address and other information as may be required by the particular survey.
- If you report a problem or submit a customer review, we will ask that you provide your name, e-mail address, membership number, address, phone number and fax number. Should you contact us for any reason other than to report a problem and/or submit a review, we may also keep a record and/or copy of your correspondence with us.
HOW DO WE PROTECT THE SECURITY AND QUALITY OF YOUR PERSONAL INFORMATION?
To protect the security and quality of your personal information, we have implemented technical and managerial procedures to maintain accurate, current and complete information as well as to protect your personal information against loss, misuse or alteration when it is under our control. Your personally identifiable information will be encrypted and stored utilizing cloud-based storage. Your personal information is also password protected so that access is limited to yourself and those with whom you share your password, Company, as well as third-party access facilitated by Company with your prior permission. We have also taken steps to help protect the integrity of your personal financial information when you complete a purchase transaction on our Website. We Stripe and Paypal to facilitate confidential online business transactions. Please visit stripe.com/ and www.paypal.com for more information.
HOW DO WE USE YOUR INFORMATION?
Our primary use of your information is to administer, maintain and improve your experience on our Website generally as well as provide you with customized, personalization services and interactive communications.
- If you check the “opt-in” feature on our Website, or if you do not uncheck a pre-checked “opt-in” box we may from time to time send you e-mails regarding our Website and special promotions. Also, we occasionally may send you direct mail about products or services that we believe may be of interest to you.
- We use your financial information (e.g., your credit card number) only to verify your credit and to bill you for memberships purchased through our Website. We also use your contact information as necessary to send you information about the memberships that you have purchased on our Website.
- When you enter any sweepstakes, contests or promotions sponsored by us or by one of our business partners, we may use your e-mail address to send you status updates.
- We use your IP address to help diagnose problems with our server and to administer the services offered on our Website. We also use your IP address to help identify you and to gather broad demographic information that we may share with our business partners, but only in the aggregate without any of your personally identifiable information.
- We may use your information to personalize your experience (your information helps us to better respond to your individual needs), improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you), and improve customer service (your information helps us to more effectively respond to your customer service requests and support needs).
- We may research the demographics, interests and behavior of our customers based on the information provided to us during membership registration, during sweepstakes, contests and promotions, from our server log files, from cookies and from surveys. Our research may be compiled and analyzed on an aggregate basis. We may share this aggregate data with business partners, but only in the aggregate, without any of your personally identifiable information.
- We may use information to respond to your inquiries and fulfill your requests, to inform you about important information regarding the Website, products or services for which you apply or may be interested in applying for, or in which you are already enrolled, changes to terms, conditions, and policies and/or other administrative information, and to deliver marketing communications that we believe may be of interest to you, including ads or offers tailored to you.
- We use your information to allow you to use some Website tools and services. Information that you enter into one of these tools and services may be stored for future access and use. You have the option not to save the information.
- We use your information for risk control, for fraud detection and prevention, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements.
CAN YOU “OPT-OUT” OF RECEIVING COMMUNICATIONS FROM COMPANY?
If you change your mind and decide that you no longer want to receive promotional e-mails and/or direct mailings, you may opt-out at any time by simply sending an e-mail request to firstname.lastname@example.org Similarly, if you are not receiving our promotional e-mails and/or direct mailings and wish to receive these materials, you may opt-in at any time by simply sending an e-mail request to email@example.com. Additionally, each email will include information for unsubscribing and/or managing email preferences.
PRIVACY POLICIES OF COMPANY PARTNERS
DO WE SELL OR RENT YOUR PERSONALLY IDENTIFIABLE INFORMATION?
No, as a general rule, we do not sell or rent your personally identifiable information to anyone. If and whenever we intend to share your personally identifiable information with a third-party (other than to a business partner as provided herein), you will be notified at the time of data collection or transfer, and you will have the option of not permitting the transfer. However, we may from time to time rent or sell demographic information in the aggregate that does not contain your personally identifiable information.
WITH WHOM DO WE SHARE INFORMATION?
We generally will not disclose any of your personally identifiable information except when we have your permission to do so or under some special circumstances described below.
- As noted previously, we may from time to time partner with other companies to offer co-branded services as well as sweepstakes, contests and promotions. Any information that you provide in connection with the co-branded services or any jointly sponsored sweepstakes, contests or promotions will become the joint property of Company and its business partners. We may also disclose other personal information about you to our business partners, but only if we have obtained your permission to make the disclosure before data collection or before transferring the data.
- We may, from time to time, offer you the opportunity to receive materials or special offers from third-parties. If you want to receive this information, we may (but only with your permission) share your name and e-mail address with them.
- Under confidentiality agreements, we may match user information with third-party data. We also may disclose aggregate demographic and/or user information and statistics in order to describe our customer base to prospective partners and other third-parties, and for other lawful purposes.
- We may disclose your personally identifiable information without your prior permission in special cases. For example, we may have reason to believe that disclosing the information is necessary to identify, contact or bring legal action against someone who may be violating the User Terms and Conditions, or may be causing intentional or unintentional injury or interference to the rights or property of Company or any third-party, including other customers. Also, we may disclose or access your personally identifiable information when we believe in good faith that law or regulation requires disclosure.
HOW CAN YOU UPDATE, CORRECT OR DELETE YOUR PERSONALLY IDENTIFIABLE INFORMATION?
You may edit your personally identifiable information and your password at any time by sending an e-mail request to firstname.lastname@example.org.
DO YOU HAVE CHOICES ABOUT COOKIES?
Yes, you have several choices with respect to cookies. You can modify your browser preferences to accept all cookies, to notify you when a cookie is set, or to reject all cookies. However, our Website uses cookie-based authentication. Accordingly, if you choose to reject all cookies, you may not be able to log onto our Website and/or use our services or participate in our sweepstakes, contests or promotions, and some features of the Website will not function properly or may be slower.
Other technologies including pixel tags, web beacons, and clear GIFs
Other technologies, such as pixel tags, web beacons and clear gifs may be used in connection with some Website pages, downloadable mobile applications and HTML-formatted email messages to measure the effectiveness of our communications, the success of our marketing campaigns, to compile statistics about usage and response rates, to personalize/tailor your experience while engaging with us online and offline, for fraud detection and prevention, for security purposes, for advertising and to assist us in resolving account holders’ questions regarding use of our Website.
As part of our solutions for online authentication, we may use Flash objects to help us recognize you and your device when you come back to the Website. For our pages running Adobe® Flash® content (demos and tutorials with moving content), we use Flash objects to determine your browser type and version of Adobe Flash in order for you to view the content. We do not use Flash objects for any online behavioral advertising purpose. Deleting cookies does not delete Flash objects. You can learn more about Flash objects – including how to control and disable them – through the Adobe interface. If you choose to disable Flash objects from our Site, then you may not be able to access and use all or part of the Site or benefit from the information and services offered.
Your IP Address is a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Website, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating Website usage levels, helping diagnose server problems, to personalize/tailor your experience while engaging with us online and offline, for compliance and security purposes, for advertising, and administering the Website. Please see the Advertising section below for more information.
Aggregated and De-identified Data
Aggregated and De-identified Data is data that we may create or compile from various sources, including but not limited to accounts and transactions. This information, which does not identify individual account holders, may be used for our business purposes, which may include offering products or services, research, marketing or analyzing market trends, and other purposes consistent with applicable laws.
Other companies offer aggregation websites and services that allow you to consolidate your financial account information from different sources (such as your accounts with us or with other financial institutions) so that you can view all your account information at one online location. To do this, an aggregation provider may request access to personal information, such as financial information, usernames and passwords. You should use caution and ensure that the aggregator company has appropriate policies and practices to protect the privacy and security of any information you provide or to which they are gaining access. We are not responsible for the use or disclosure of any personal information accessed by any company or person to whom you provide your Website username and password.
If you provide your Website username, password or other information about your accounts with us to an aggregation website, we will consider that you have authorized all transactions or actions initiated by an aggregation website using access information you provide, whether or not you were aware of a specific transaction or action. If you decide to revoke the authority you have given to an aggregation website, we strongly recommend that you change your password for the Website to ensure that the aggregation website cannot continue to access your account.
We may allow certain widgets (e.g., social share buttons) on our Website that enable users to easily share information on another platform, such as a social media platform. The third parties that own these widgets may have access to information about your browsing on pages of our Websites where these widgets are placed. You may wish to review information at the third-party site, such as social media platforms where you have an account, to determine how these third parties collect and treat such information.
Social media sites
Making sure information is accurate
Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please use the Contact Us option on our Website, or call or write to us at the telephone numbers or appropriate address for changes shown in the Website Terms and Conditions of Use.
Protecting children’s privacy online
The Website is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide personal information through the Website. We do not knowingly collect information from children under 13 without parental consent. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA).
Protecting individual health information
To the extent that we receive, maintain or process an individual’s protected health information, Company may disclose that information as authorized by and in accordance with applicable federal and/or state law.
Change of Control / Asset Transfer
As the Company develops, we may buy other businesses or their assets or sell all or parts of our business assets. Customer information is generally one of the business assets involved in such transactions. Thus, in the event that the assets of the Company in whole or in parts are acquired by a third-party, customer information, including any visitor information collected through the Website or the Online Service, would be one of the transferred assets.
In the event of a corporate change in control or sale of all or parts of our business assets our users will be notified in accordance with the “Updates to this Privacy Notice” section below if their personal information is provided to the new corporate entity or asset purchaser.
Updates to this Privacy Notice
WHAT ELSE SHOULD YOU KNOW ABOUT YOUR ONLINE PRIVACY?
Any capitalized but undefined terms used herein shall have the meaning set forth in the Company’s Website Terms and Conditions of Use.
If you have any questions or comments about this Privacy Statement or the practices of our Website, please feel free to e-mail us at email@example.com or visit our contact page.
EFFECTIVE AS OF: August 1, 2019