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.